In the 1961 case of Link v. Wabash Railroad Co., the U.S. Supreme Court ruled that a federal court has the inherent authority to dismiss a case for failure to prosecute, even without express authorization from court rules or statutes. The plaintiff, Mr. Link, had brought an action against Wabash Railroad Company under Federal Employers' Liability Act (FELA). However, his attorney failed to appear at a pretrial conference and did not provide any explanation for his absence despite being given ample opportunity by the District Court judge who eventually dismissed Link's lawsuit due to this non-compliance with procedural requirements. On appeal, Mr. Link argued that only explicit rule-based or statutory authority could justify such dismissal but was overruled by both Appeals and Supreme Courts which upheld trial courts' inherent power in managing their dockets effectively.

In the dissenting opinion for Link v. Wabash Railroad Co., it was argued that the dismissal of a case due to an attorney's absence from court, without any prior notice or opportunity given to rectify this mistake, is too harsh a punishment and violates principles of fairness. The dissent emphasized that such action could potentially harm clients who are innocent bystanders in their attorneys' negligence or misconduct. It pointed out that while courts have inherent power to manage their affairs and ensure compliance with orders, they should exercise these powers judiciously and not use them as tools for punishing litigants whose only fault lies in choosing irresponsible legal representatives. Furthermore, it was suggested that there were other less drastic measures available which could have been used instead of outright dismissal.