Hyde v. Van Wormer

Background

The dispute involved motions for damages and costs after a petition for review. Two groups — federal government respondents and Inland Steel Co. and its co-respondents — moved under the Court’s Rule 49.2 seeking damages. The Court granted motions and awarded $500 to the federal respondents and $500 to Inland Steel Co. et al. The Court denied Inland Steel’s request for double costs and denied the petitioner’s motion for costs and fees.

Reasoning

The Court applied Rule 49.2, which allows awards when an appeal or petition is frivolous. Pursuant to that rule, the Court ordered $500 damages for each awarded respondent. The opinion as provided does not offer a detailed explanation for the dollar amount. Justice Brennan, joined by Justices Marshall and Stevens, argued that Rule 49.2 sets no standards for when a petition is “frivolous” or how to decide an “appropriate” damages amount, and he criticized the Court for making no effort to justify the $500 figure. The opinion notes that Justice Blackmun also dissented from the awards.

Real world impact

As written, the decision results in $500 payments to the federal respondents and to Inland Steel Co. et al., and the petitioner will not recover costs or fees. The dissent warns that without clear standards, future damage awards under Rule 49.2 could appear arbitrary. This is a narrow, procedural ruling about sanctions and costs rather than a decision on the underlying dispute.

Dissents or concurrances

Justice Brennan’s dissent, joined by Justices Marshall and Stevens, objects to the awards as unsupported and arbitrary; Justice Blackmun also dissented from the damages.