National Hockey League v. Metropolitan Hockey Club, Inc.
United States Supreme Court
427 U.S. 639 (1976)
Plaintiff M-GB, along with other plaintiffs, sued the National Hockey League and others (defendants) for antitrust violations, but failed over 17 months to adequately respond to interrogatories despite multiple court-granted extensions and explicit warnings that Rule 37 sanctions could follow; the district court ultimately found M-GB had acted in flagrant bad faith and dismissed its case. The Third Circuit reversed, finding insufficient evidence of bad faith and noting the defendants themselves had not seriously pursued the discovery responses until settling with the other plaintiffs, after which M-GB's new counsel had difficulty gathering the requested information.
Whether a court may dismiss a complaint under Rule 37 of the Federal Rules of Civil Procedure because the plaintiff failed to respond to a discovery order in bad faith.