Allied Chemical Corp. v. Daiflon, Inc.

Background

A small importer of refrigerant gas sued domestic manufacturers, accusing them of monopolizing the market and conspiring to drive it out of business. After a four-week trial a jury awarded the importer $2.5 million. The trial judge denied a motion to set aside the verdict but granted a new trial, citing evidentiary errors and doubts about the damages award. The importer then asked the court of appeals for a writ of mandamus to force reinstatement of the jury verdict; the court of appeals, without a full trial transcript, ordered liability restored while allowing a new trial on damages.

Reasoning

The core question was whether an appellate court can use the extraordinary writ of mandamus to review a trial court’s discretionary new-trial order. The Court explained that mandamus is a drastic, rarely used remedy meant only to confine a lower court to lawful jurisdiction or to compel it to act when it must. Allowing mandamus in routine new-trial situations would undermine the long-standing rule that most appellate review waits until final judgment and would encourage piecemeal appeals. Because new-trial decisions rest largely in the trial judge’s discretion and the record before the court of appeals was incomplete, the Court concluded the importer's right to the writ was not “clear and indisputable,” and it reversed the court of appeals’ use of mandamus.

Real world impact

The decision keeps in place the usual rule that parties must generally wait for final judgment before seeking appellate review of a new-trial order. It protects trial judges’ authority to order new trials and limits immediate appellate intervention. The ruling is procedural and does not decide the underlying antitrust dispute.

Dissents or concurrances

Justice Blackmun, joined by Justice White, dissented, arguing the case looked unusual and deserved full review on a complete record rather than a summary reversal.