Degen v. United States

Summary

The Supreme Court held that a federal district court may not invoke the fugitive disentitlement doctrine to strike a claimant's filings and enter summary judgment against him in a civil forfeiture action merely because he remains abroad and unavailable for a related criminal prosecution. Justice Kennedy reasoned that the rationales supporting appellate disentitlement—enforceability of judgments, deterrence of flight, and judicial dignity—do not justify absolute disentitlement where the court already controls the res and can protect the Government through protective orders, case management, and ordinary sanctions. Because a court's inherent power is limited by the necessity giving rise to its exercise, and no necessity existed here, the Court reversed the Ninth Circuit and remanded. No separate opinions were filed.