Delaware, Lackawanna & Western Railroad v. Rellstab

Background

A man who had sued a train company for injuries to himself, injury to a minor son, and the death of another son won a judgment in December 1921 after a crossing collision. That judgment was later set aside because two key witnesses, a husband and wife, admitted they had committed perjury at the first trial. At a second trial the railroad won and the new judgment was entered on June 21, 1923, and later affirmed by the federal appeals court in March 1924. After the court term had ended, the husband swore that his testimony at both trials was false. The trial judge then tried to set aside the affirmed judgment on May 9, 1925.

Reasoning

The Court addressed whether a trial judge can cancel a final judgment after the court term has ended and whether the appeals court can force reinstatement. The opinion explains that the judge lost power to vacate the judgment once the term ended. Because the trial court had no jurisdiction to undo an affirmed judgment, the proper response is for the appeals court to require enforcement. The Court reasoned that the appeals court, having affirmed the judgment, has authority to protect its decision from improper actions by the lower court and to order reinstatement.

Real world impact

The ruling makes clear that final judgments cannot be reopened by a trial judge after the term ends and that appeals courts may step in to restore those judgments when a lower court exceeds its authority. The decision promotes finality, prevents sudden nullification of resolved cases due to late recantations, and keeps the appeals process effective and enforceable.