Rosalinn M. Giang v. David Steiner, Postmaster General

Summary

The court grants the defendant’s motion for sanctions in an employment-discrimination action against the Postmaster General. It finds that the plaintiff filed multiple fabricated or forged witness statements, failed to comply with court-ordered limited discovery, and willfully interfered with the judicial process. Applying the Ehrenhaus factors, the court dismisses the action with prejudice.

Holdings

1. A district court may impose sanctions, including dismissal, under Federal Rule of Civil Procedure 37(b)(2)(A)(v) when a party fails to obey an order to provide or permit discovery, and may also impose appropriate sanctions under its inherent authority to protect the integrity of judicial proceedings.
2. Dismissal with prejudice was warranted because Plaintiff willfully engaged in bad-faith litigation conduct, caused actual prejudice, interfered substantially with the judicial process, had been warned that dismissal was a possible sanction, and could not be adequately deterred by lesser sanctions.

Questions Presented

1. Whether Plaintiff's submission of fabricated or forged witness statements and failure to comply with fraud-related discovery warranted sanctions under Federal Rule of Civil Procedure 37 and the court's inherent authority.
2. Whether dismissal with prejudice was an appropriate sanction under the applicable factors governing dismissal for litigation misconduct.

Disposition

dismissed