S&T Bank v. Groskop
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In this complaint brought by Black Diamond Energy and Black Diamond Energy of Delaware (together, the BDE Companies) and seventeen limited partnerships (the Limited Partnerships) the Supreme Court affirmed the judgment of the district court dismissing with prejudice the complaint, holding that the district court did not abuse its discretion in dismissing the case with prejudice.
The complaint alleged that S&T Bank's lending policies in the wake of the 2008 economic recession caused severe financial loss to the seventeen limited partnerships (the Limited Partnerships) managed by Black Diamond Energy and Black Diamond Energy of Delaware (together, the BDE Companies). Daniel Groskop, the trustee of a trust formed by the Limited Partnership, was later substituted for the Limited Partnerships as the true party in interest on the condition that the BDE Companies' claims against the Bank be dismissed with prejudice. Due to Groskop's noncompliance with discovery orders and the Wyoming Rules of Civil Procedure, the district court dismissed the case with prejudice. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it concluded that Groskop's violation of two court orders compelling discovery, two orders awarding attorneys' fees, and the failure to fulfill the representative duties associated with Wyo. R. Civ. P. 30(b)(6) required dismissal with prejudice.
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