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United States v. Shaffer Equipment Co.

United States Court of Appeals for the Fourth Circuit
11 F.3d 450 (1993)


The federal government, on behalf of the United States Environmental Protection Agency (EPA) (plaintiff), filed suit in federal district court against Shaffer Equipment Company (Shaffer) (defendant), under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), to recover over $5 million incurred in cleaning up a hazardous waste site located on Shaffer’s West Virginia property. During discovery, a federal investigation uncovered that the project coordinator for the Shaffer cleanup, Robert Caron, had repeatedly lied about having a college degree from Rutgers University. Further, investigators found that government attorneys, Snyder and Hutchins, obstructed defense counsel’s efforts to uncover Caron’s misrepresentation. The district court temporarily stayed the proceedings. When the EPA reported to the court that it would continue with its case, defense counsel filed a motion to dismiss the action for bad faith conduct. After a two-day hearing on the motion, the district court found that Snyder and Hutchins violated their duty of candor to the court and failed to supplement discovery with material information. The district judge dismissed the EPA’s case with prejudice. The federal government appealed.

Rule of Law


Holding and Reasoning (Niemeyer, J.)

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