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In Poulis v. State Farm Fire & Casualty Co., the Third Circuit Court of Appeals held that a district court must consider six factors dismissing a case as a sanction before trial on the merits: extent of the party's personal responsibility, prejudice to the adversary caused by the failure to meet scheduling orders and respond to discovery, history of dilatoriness, whether the conduct of the party or the attorney was willful or in bad faith, effectiveness of sanctions other than dismissal, and meritoriousness of the claim or defense.
This week, the court held that Poulis does not apply in the post-trial context.
In 2008, Tera Knoll sued the City of Allentown for gender discrimination, harassment, and retaliation following her termination from the City's Parks Department. Some of her claims were dismissed at summary judgment, some in a motion for judgment as a matter of law. The jury returned a verdict in favor Allentown on the remaining claims.
Knoll moved for a new trial; Allentown responded that the motion was meritless, and that Knoll had failed to comply with local rules in her request. More legal wrangling ensued, none of which actually led to a new trial.
Knoll eventually brought her case to the Third Circuit Court of Appeals, still seeking a new trial. She argued that the district court erred when it failed to consider the Poulis factors before dismissing and denying the motions pursuant to local rules. The appellate court disagreed, finding that review of the Poulis factors is not required when a district court dismisses a post-trial motion for noncompliance with procedural rules or court orders.
In ruling against Knoll, the appellate court noted, "The concern animating Poulis -- that dismissal will deprive a party of her day in court and preclude review of potentially meritorious claims -- does not apply in the post-trial context. After all, the parties have already received an adjudication on the merits."
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