The power of our courts to wield certain implied powers “must necessarily result to our [c]ourts of justice from the nature of their institution.” Dietz v. Bouldin is the story of how a common Montana traffic accident reached the highest court in the land by questioning the extent of this necessary power. The case specifically raised the question of whether a federal district court could recall and re-empanel an already excused and discharged jury. In a 6–2 decision, the United States Supreme Court chose efficiency over prudence and modernity over convention by holding a federal judge does wield such power.
Erik Anderson, Case Note, Dietz v. Bouldin: Testing the Limits of a District Court's Limited Inherent Power, 78 Mont. L. Rev. Online 1, https://scholarship.law.umt.edu/mlr_online/vol78/iss1/1.