Dellums v. Powell

How later courts described this case

• holding that “Rule 60(b) applies only to modifications of final judgments”
• finding abuse of discretion where trial court vacat *1332 ed dismissal of a plaintiff who failed to answer interrogatories
• finding abuse of discretion where trial court vacated dismissal of a plaintiff who failed to answer interrogatories
• “[H]owever innocent a failure to provide discovery may be, it is fundamental that a party that does not provide discovery cannot profit from its own failure_ [Parties failing to comply with discovery requests may be estopped from ‘support[ing] or oppos[ing] designated claims or defenses.’ ”

Written by the judges who cited it.