Chambers v. Nasco, Inc.
Is it still good law? What later courts have actually done to this case.
Status
6,270 later cases cite Chambers v. Nasco, Inc.; 198 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Chambers v. Nasco, Inc.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The panel held that Chambers supports compensatory inherent-power sanctions imposed without contempt procedures, but not a punitive penalty.
Miller v. Cardinale (In re DeVille) · Bankruptcy Appellate Panel of the Ninth Circuit · filed
It is apparent from Chambers that “inherent authority” will not suffice to support such a “penalty” in this instance. The award in Chambers was purely compensatory. The context of the Chambers rationale is that “inherent power” is not a manifestation of contempt power and may be determined without resort to contempt proceedings so long as the sanctions are compensatory.
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The Third Circuit confined Chambers's inherent power to vacate a fraudulently procured judgment to civil cases and refused to extend it to a criminal sentence.
In re Washington · Third Circuit · filed
However, both Hazel-Atlas and Chambers are civil cases. In the criminal context, the Supreme Court has held that district courts lack “inherent supervisory power” to enter an untimely judgment of acquittal sua sponte when doing so is in clear contradiction of Federal Rule of Criminal Procedure 29(c). Carlisle v. United States, 517 U.S. 416, 425-28, 116 S.Ct. 1460, 1466-67, 134 L.Ed. 2d 613 (1996). The Court explained, “[w]hatever the scope of this ‘inherent power,’ however, it does not include the power to develop rules that circumvent or conflict with the Federal Rules of Criminal Procedure.” Id. at 426, 116 S.Ct. at 1466. The Court recognized its holding in Chambers, but distinguished it “not only because of the clarity of the text [of Rule 29(c)], but also because we are unaware of any ‘long unquestioned’ power of federal district courts to acquit for insufficient evidence sua sponte, after return of a guilty verdict.” Id. Likewise, this Court is unaware of “any ‘long unquestioned’ power of federal district courts” to vacate a judgment procured by fraud in the criminal context. Id.
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The Third Circuit declined to extend Chambers's inherent-power doctrine to sua sponte dismissal of an indictment after repeated hung juries.
United States v. Wright · Third Circuit · filed
neither the Supreme Court nor our Court has extended a court's inherent authority to allow the sua sponte dismissal of an indictment solely to preclude multiple mistrials following hung juries, see Chambers
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Does this case still carry your argument?
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