In re Univ. of Mich., 936 F.3d 460

Background

John Doe sued the University of Michigan claiming due-process violations in a disciplinary hearing; this case was remanded after this circuit’s Doe v. Baum decision requiring live hearings and cross-examination.
On remand, the district judge scheduled a settlement conference and insisted the University’s president attend in person, rejecting requests to attend by phone or to send a different representative with full settlement authority.
The University had offered a representative with full settlement authority; the judge nevertheless demanded the president personally attend and participate.
Two days before the conference the district judge converted the previously-assured private settlement conference into a public, on-the-record proceeding, citing public interest and media coverage.
The University petitioned this court for a writ of mandamus to block the judge’s orders, arguing the district court lacked statutory or constitutional authority to require the president’s personal attendance or to make the conference public.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a district court may compel a specific high-ranking state official (University president) to attend a settlement conference in person	The president must explain University policy and is an appropriate on-the-record participant	University offered a representative with full settlement authority and requested phone attendance or a delegate; compelling the president is unnecessary and intrusive	Court: Abused discretion; Rule 16 and inherent powers do not permit forcing a specific high-ranking state official when an authorized representative is available
Whether a district court may convert a private settlement conference into a public, on-the-record proceeding because of "public interest"	Public interest justifies openness and transparency	Settlement conferences should be private to promote candid negotiations; Rule 16 purposes do not include public airing	Court: Abused discretion; ordering the conference public undermines confidential settlement process and Rule 16 purposes
Whether the district court’s actions are authorized by Congress, Article III inherent powers, or otherwise	Judicial inherent powers allow reasonable case-management measures, including compelling attendance	Such powers are limited, must be necessary to adjudication, and cannot override federalism and procedural limits	Court: No statutory or constitutional basis; actions exceeded lawful authority and implicated federalism/separation concerns
Whether mandamus relief is appropriate to remedy the district court’s orders	Mandamus unnecessary; ordinary remedies suffice	Mandamus warranted because no adequate alternative, clear abuse of discretion, and intrusion on federal-state relations	Court: Granted mandamus — extraordinary relief appropriate to prevent judicial overreach

Key Cases Cited

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts’ power derives from Congress and the Constitution)
Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (inherent powers exist but must be necessary and incidental to courts’ functions)
Doe v. Baum, 903 F.3d 575 (6th Cir. 2018) (remand requiring live hearings and cross-examination in student-discipline context)
Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003) (importance of confidentiality and candor in settlement negotiations)
In re LaMarre, 494 F.2d 753 (6th Cir. 1974) (Rule 16 allows court to require party representatives, but limits exist)
United States v. U.S. Dist. Court for N. Mariana Islands, 694 F.3d 1051 (9th Cir. 2012) (mandamus where district court compelled government settlement representative)
In re Stone, 986 F.2d 898 (5th Cir. 1993) (abuse of discretion in ordering government to send settlement-authority representatives to private conferences)
Cheney v. U.S. Dist. Court for D.C., 542 U.S. 367 (2004) (mandamus is extraordinary relief; standards for issuance)
Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803) (mandamus historical standards for extraordinary relief)