The following excerpt is from U.S. v. Real Property Rialto Acres Located in Fontana, Cal., 76 F.3d 390 (9th Cir. 1996):
The five factors in Wanderer are: (1) the public's interest in expeditious resolution of litigation; (2) the court's need to manage its dockets; (3) the risk of prejudice to the party seeking sanctions; (4) the public policy seeking disposition of cases on their merits; and (5) availability of less drastic sanctions. 910 F.2d at 656. The district court is not required to make explicit findings regarding these factors, but if it does not, as is the case here, this court reviews the record independently to determine whether the sanction was an abuse of discretion. U.S. for the use and benefit of Wiltec Guam v. Kahaluu Const., 857 F.2d 600, 603 (9th Cir.1988).
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