Bradley v. American Household, Inc.

378 F.3d 373 (2004)

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Bradley v. American Household, Inc.

United States Court of Appeals for the Fourth Circuit
378 F.3d 373 (2004)

Facts

Sunbeam Corporation (defendant), a maker of electric bedding products, had a policy of retaining returned products that were subject to legal actions. Dale and Tammy Bradley (the Bradleys) (plaintiffs) experienced a house fire that they alleged was caused by a defective electric blanket from Sunbeam. The Bradleys brought suit against Sunbeam in federal district court and made a discovery request for the remains of returned electric blankets and the associated claims files. The court ordered Sunbeam to produce the requested items. At a later hearing, the court found that Sunbeam had willfully refused to comply with the order. The Bradleys and Sunbeam entered a settlement agreement, which included a commitment from Sunbeam to produce the blankets and documents. However, dissatisfied with Sunbeam’s efforts, the Bradleys reopened the case. The court found that Sunbeam had discarded returned blankets following both the Bradleys’ initial discovery request and the court order. The court imposed fines of $200,000 against Sunbeam and $100,000 against Sunbeam’s attorney. These fines were payable to the court and not conditioned on compliance with the order. The court also ordered Sunbeam to pay the Bradleys’ legal fees. Sunbeam appealed, arguing that the sanctions were criminal in nature and thus required a finding of criminal contempt.

Rule of Law

Issue

Holding and Reasoning (Wilkinson, J.)

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