Hazel-Atlas Glass Co. v. Hartford-Empire Co.

322 U.S. 238



Under certain circumstances, one of which is after-discovered fraud, relief will be granted against judgments regardless of the term of their entry.


Petitioner commenced suit in the appellate court by filing a petition for leave to file a bill of review in the district court to set aside a judgment entered by the district court nine years prior pursuant to the appellate court's mandate. Petitioner contended that the appellate court's judgment had been obtained by fraud; it supported the charge with affidavits and exhibits. The action was spurred on by respondent's allegations that petitioner was infringing upon its patent. Certain issues were not made known to petitioner until nine years later, when it decided to institute the present suit. The appellate court entered judgment in favor of respondent and held that the fraud was not newly discovered and that it lacked the power to set aside the district court's decree because of the expiration of the term during which the previous decision had been rendered.


Even if petitioner failed to exercise due diligence to uncover the fraud, may relief be denied on that ground alone, if public interests are involved?




The United States Supreme Court reversed the lower court's decision when the court found that, under certain circumstances, one of which was after discovered fraud, relief would be granted against judgments regardless of the term of their entry. The Court held that the appellate court had both the duty and the power to vacate its own judgment and to give the trial court appropriate directions because every element of the fraud demanded the exercise of the power to set aside fraudulently begotten judgments.

Click here to view the full text case and earn your Daily Research Points.