Link v. Wabash R.R. Co

In Link v. Wabash R.R. Co., 370 U.S. 626 (1962), the Supreme Court upheld the trial court's dismissal of a civil action based on the party's counsel's failure to appear at a scheduled hearing. The Court reasoned that to allow the party to proceed with its claim would effectively punish the opposing party for the other party's error. Id. at 634. The plaintiff's attorney failed to attend a mandatory pretrial conference. The plaintiff's attorney left a message with the court prior to the pretrial conference seeking a continuance. However, he did not attend the pretrial conference. Two hours later, the court dismissed his case, stating that the "dismissal was in the 'exercise of its inherent power.'" The United States Supreme Court affirmed the judgment and noted that "the authority of a court to dismiss sua sponte for lack of prosecution has generally been considered an 'inherent power,'. . . necessarily vested in courts to manage their own affairs so as to achieve the orderly and expeditious disposition of cases." Id. at 630-631. The United States Supreme Court concluded that the specific circumstances present in that case warranted dispensing with the necessity for advance notice and a pre-dismissal hearing because the petitioner had constructive knowledge of the consequences for failing to attend a scheduled a pretrial hearing by virtue of the dilatory history of the proceedings. See Link, 370 U.S. at 632-33. The court then commented that the petitioner had also failed to avail himself of the opportunity to demonstrate he was entitled to relief despite the notice by moving for relief pursuant to the federal counterpart to 806.07. See id.