Poulis v. State Farm Fire and Casualty Co.
United States Court of Appeals for the Third Circuit
747 F.2d 863 (1984)
The Poulises (plaintiffs) sued State Farm (defendant) over a denied fire-insurance claim, but their attorney Retos repeatedly missed discovery deadlines and never filed a required pre-trial statement, leading the district court to dismiss with prejudice; after the Third Circuit vacated that first dismissal because the Poulises themselves weren't responsible for their attorney's lapses, the district court on remand considered alternative sanctions, found none appropriate, and dismissed again, prompting a second appeal.
Whether a court should weigh personal responsibility, prejudice, history of dilatoriness, bad faith, availability of alternative sanctions, and the merits of the claim in deciding whether dismissal is a justified sanction under the Federal Rules of Civil Procedure.