United States v. Shaffer Equipment Co

Facts

Robert E. Caron was the On-Site Coordinator for a United States Environmental Protection Agency (EPA) (Plaintiff) clean-up site. Caron claimed to have a B.S. in environmental science from Rutgers University and an M.S. in organic chemistry from Drexel, but neither university had records to show Caron had received such degrees. J. Jarod Snyder, a Department of Justice attorney, represented the EPA (Plaintiff), including Caron, at depositions. Snyder knew that Caron had not received a degree from Rutgers. Caron testified at his deposition concerning his alleged educational background, and Snyder objected to the continued questions as irrelevant but he did not reveal the truth about Caron’s credentials. When counsel for the defense suggested obtaining a court ruling on the objection, Snyder requested a recess and contacted his superior, William A. Hutchins. Snyder was advised to inform Caron he may wish to stop answering and seek individual counsel. Caron elected to continue answering and Snyder continued to state objections to the line of questioning regarding Caron’s credentials. Defense counsel argued the questions were relevant because they regarded Caron’s credibility. After research, Snyder determined the questions were relevant but still failed to alert defense counsel or withdraw the objections. The Inspector General later began a criminal investigation into Caron’s misrepresentations, but no one alerted the court or defense counsel to the ongoing investigation. In addition, Snyder based his motion for summary judgment on Caron’s administrative documents although he did not cite to Caron’s administrative documents although he did not mention Caron’s testimony or include Caron’s affidavit. He still did not inform the court or defense counsel of Caron’s misrepresented credentials. Hutchens continued to advise Snyder to delete reference to the criminal investigation in correspondence and avoid notifying the court or defense counsel. Defense counsel then independently learned Caron falsely testified in another case and so informed the Assistant United States Attorney. At that time, EPA (Plaintiff) informed the court and defense counsel of the “Caron problem” and requested a stay. The district court held that Snyder and Hutchins violated their duty of candor to the court and failed to supplement discovery with material information. The court sanctioned counsel by dismissing the action in its entirety and awarding costs to the defendant. Plaintiff appealed