Sampson v. Welch
SAMPSON v. WELCH, Collector of Internal Revenue
- Proceeding
- district
- Area
- civil
- Panel
- Jenney (author)
Analysis
The court vacated its prior opinion in Sampson v. Welch after determining that the Ninth Circuit's decision in United States v. Goodyear was controlling precedent on the identical legal issues. The court ordered counsel to prepare findings, conclusions, and a judgment consistent with the Goodyear decision for the court's signature.
| What the court decided | The model |
|---|---|
Prior opinion vacated and withdrawn“It is therefore hereby ordered that the opinion heretofore rendered in this case be and it is hereby vacated and withdrawn” | agree with court The court correctly identified that a binding appellate decision from the Ninth Circuit (United States v. Goodyear) controlled the legal issues in the district court case. Under the principle of vertical stare decisis, a district court must follow the precedent of the circuit in which it sits, even if the district court previously expressed a contrary view. Vacating the prior opinion to conform to the controlling authority is the procedurally correct action. |
Order to prepare findings and judgment consistent with Goodyear“findings, conclusions and judgment in accordance with the opinion in United States v. Goodyear, supra, be prepared by counsel for plaintiff herein, for presentation to this court for signature in accordance with the provisions of Rule 8 of the rules of this court.” | agree with court The court directed the preparation of a judgment that aligns with the controlling precedent. This is a standard procedural step to ensure the final judgment reflects the correct legal standard established by the appellate court. |
The order itself: sound — The order is procedurally sound. It correctly applies the doctrine of stare decisis by recognizing that the Ninth Circuit's decision in Goodyear is binding on the District Court for the Southern District of California. The court explicitly acknowledges that its prior opinion expressed a different view but correctly subordinates that view to the controlling appellate precedent. The order is concise and directly addresses the conflict between the district court's prior reasoning and the binding circuit authority.
Opinion — Jenney
JENNEY, District Judge.
The opinion of the United States Circuit Court of Appeals for the Ninth Circuit in the case of United States v. Goodyear, 99 F.2d 523, having been called to the court’s attention; and it appearing to the court from an examination of said opinion that that case involved facts almost identical, in legal effect, with those in the case at bar; and it further appearing to this court that the said decision of the Ninth Circuit Court of Appeals in said Goodyear case is controlling, as a matter of legal precedent, over the issues in the case at bar, even though the opinion heretofore rendered in this cause (Sampson v. Welch, D.C., 23 F.Supp. 271) expresses the views of this court as to a proper determination of said issues, It is therefore hereby ordered that the opinion heretofore rendered in this case be and it is hereby vacated and withdrawn; that findings, conclusions and judgment in accordance with the opinion in United States v. Goodyear, supra, be prepared by counsel for plaintiff herein, for presentation to this court for signature in accordance with the provisions of Rule 8 of the rules of this court.
So ordered.
Cites, in this corpus
- Sampson v. Welch 7317-S · 1938-04-30