Law School Case Brief
Casey v. Planned Parenthood - 14 F.3d 848 (3d Cir. 1994)
Law of the case rules have developed to maintain consistency and avoid reconsideration of matters once decided during the course of a single continuing lawsuit. Of these rules, the most compelling is the mandate rule. This fundamental rule binds every court to honor rulings in the case by superior courts. An inferior court has no power or authority to deviate from the mandate issued by an appellate court.
Planned Parenthood of Southeastern Pennsylvania et al. (Planned Parenthood) brought an action against appellant Commonwealth of Pennsylvania challenging the constitutionality of a state abortion statute. Ultimately, the United States Supreme Court issued a mandate and remanded the case. However, on remand from the Court, the district court reopened the case and granted Planned Parenthood’s request for an injunction and their motion for a new trial. The Commonwealth sought further review from the United States Court of Appeals for the Third Circuit.
Was the federal district court precluded from reopening a case, the merits of which had already been decided by the United States Supreme Court?
The appellate court reversed and remanded the district court's order concluding that law of the case rules precluded the district court's authority to reopen the case. The court further held that because the Supreme Court had clearly decided the merits of the case and had directed that its opinion be carried out, the lower court was without authority to grant Planned Parenthood’s request for injunctive relief and motion for a new trial. Finally, the court rejected Planned Parenthood’s contentions that exceptions to the law of the case doctrine applied because the exceptions did not apply where it would have been contrary to the Supreme Court's mandate.
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