United States v. United States Steel Corp.
Headline: Court rules a large trial record need not be converted to a narrative under Equity Rule 75, allows original testimony volumes to serve as the appeal record, and denies extra time for narrative reduction.
Holding: In this case, the Court held that the existing printed original testimony volumes made this an exception to Equity Rule 75, so those volumes should form the record on appeal and no extra time for narrative reduction was required.
- Allows original printed testimony volumes to be used as the appeal record.
- Reduces need to convert very large testimony sets into narrative form in similar cases.
- Extends filing deadline sixty days from March 15 for preparing the record.
Summary
Background
The United States asked the lower court for more time, until July 1, to finish converting extensive trial testimony into a narrative form under Equity Rule 75. The defendant objected, wanting the original testimony brought up and arguing the case should not be governed by the Rule. The record already consists of 30 printed volumes totaling 12,151 pages, with 14 volumes (about 5,969 pages) taken before the Rule became effective; digests and indexes were prepared and used below.
Reasoning
The central question was whether Equity Rule 75 required the testimony to be reduced to a narrative for the appeal. The Court concluded this case is an exception to Equity Rule 75 and should not be controlled by it. Because the original printed volumes already existed and had been used by the lower court, the Court held those volumes should constitute part of the record on appeal. For that reason, the Court found no basis to grant more time solely to complete a narrative reduction.
Real world impact
Practically, the ruling lets the already printed original testimony volumes be used on appeal in this case instead of forcing a narrative reduction. The Court nonetheless extended the deadline to file the record by sixty days from March 15 to give parties time to prepare the record consistent with this decision. This is a procedural ruling affecting how voluminous records are presented on appeal in similar circumstances.
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