Payne v. Exxon Corp

In Payne v. Exxon Corp., 121 F.3d 503 (1997), Exxon's motion to compel was granted after its initial discovery requests were ignored by plaintiffs. Plaintiffs failed to comply with the court's order compelling discovery, and Exxon moved to dismiss the case. VECO, a co-defendant and non-discovering party, joined Exxon's motion to dismiss. The Court recognized that VECO lacked standing to move to compel answers to Exxon's discovery requests because it was not a discovering party. The Court held that dismissal of the case was proper against both Exxon and VECO, relying on the broad authority of a court to impose sanctions for failure to comply with a discovery order. Payne, 121 F.3d at 510 ("If Congress had intended to limit the district court's dismissal authority to claims against the party who propounded discovery, it would not have chosen such sweeping language.").