Degen v. United States, 517 U.S. 820 (1996)

Page:   Index   1  2  3  4  5  6  7  8  9  10  Next





certiorari to the united states court of appeals for the ninth circuit

No. 95-173. Argued April 22, 1996—Decided June 10, 1996

Petitioner Degen is outside the United States and cannot be extradited to face federal drug charges. When he filed an answer in a related civil action, contesting the Government's attempt to forfeit properties allegedly purchased with proceeds from his drug dealings, the District Court struck his claims and entered summary judgment against him, holding that he was not entitled to be heard in the forfeiture action because he remained outside the country, unamenable to criminal prosecution. The court's final order vested title to the properties in the United States, and the Court of Appeals affirmed.

Held: A district court may not strike a claimant's filings in a forfeiture suit and grant summary judgment against him for failing to appear in a related criminal prosecution. Pp. 822-829. (a) The Government contends that the District Court's inherent powers authorized it to strike Degen's claims under what has been labeled the "fugitive disentitlement doctrine." Principles of deference counsel restraint in resorting to the courts' inherent authority to protect their proceedings and judgments in the course of discharging their traditional responsibilities, see, e. g., Chambers v. NASCO, Inc., 501 U. S. 32, 44, and require its use to be a reasonable response to the problems and needs provoking it, Ortega-Rodriguez v. United States, 507 U. S. 234, 244. Pp. 822-824. (b) No necessity justifies disentitlement here. Since the court's jurisdiction over the property is secure despite Degen's absence, there is no risk of delay or frustration in determining the merits of the Government's forfeiture claims or in enforcing the resulting judgment. The court has alternatives, other than the harsh sanction of disentitlement, to keep Degen from using liberal civil discovery rules to gain an improper advantage in the criminal prosecution, where discovery is more limited. Disentitlement also is too arbitrary a means of redressing the indignity visited upon the court by Degen's absence from the criminal proceedings and deterring flight from criminal prosecution by Degen and others. A court's dignity derives from the respect accorded its judgments. That respect is eroded, not enhanced, by excessive

Page:   Index   1  2  3  4  5  6  7  8  9  10  Next

Last modified: October 4, 2007