United States Third Circuit

Poulis v. State Farm Fire and Casualty Co., which held that a district court must consider six factors before it may dismiss a case as a sanction before trial on the merits, does not apply in the post-trial context because the concern underlying Poulis that dismissal will deprive a party of her day in court and preclude review of potentially meritorious claims does not apply in the post-trial context, and therefore the district court did not err in dismissing plaintiff's post-trial motions for noncompliance with procedural rules or court orders.

Appellate Information

• Decided 02/21/2013
• Published 02/21/2013

Judges

• HARDIMAN

Court

• United States Third Circuit

Counsel