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In the case of La Buy v. Howes Leather Co., Inc., et al, 1956, the U.S. Supreme Court ruled that a district judge had overstepped his authority by appointing a special master to oversee two complex antitrust cases without first determining whether it was necessary or appropriate to do so. The court found that this action violated Rule 53(b) of the Federal Rules of Civil Procedure which states that reference to a master should only be made in exceptional circumstances where it is not practicable for the court itself to address certain issues. In this case, there were no such exceptional circumstances and thus, Judge La Buy's decision was deemed an abuse of discretion leading to reversal and remandment by higher courts.
In the dissenting opinion for La Buy v. Howes Leather Co., Inc., Justice Harlan argued that the majority's decision to reverse and remand was an overreach of their supervisory power. He contended that there were no legal grounds for such a reversal, as it was not proven that Judge La Buy had abused his discretion in appointing a special master to oversee complex antitrust litigation cases. The use of masters, according to Justice Harlan, is within the purview of district courts' inherent powers and should be left up to their judgment unless clear abuse can be demonstrated. In this case, he believed there wasn't any evidence showing such misuse or violation of Federal Rule 53(b). Therefore, he disagreed with the majority's view on reversing Judge La Buy’s decision based on what they perceived as inappropriate delegation.