The U.S. Supreme Court case National Hockey League et al. v. Metropolitan Hockey Club, Inc., et al., 1975 revolved around the issue of discovery sanctions in a lawsuit between the National Hockey League (NHL) and its member teams against the Metropolitan Hockey Club (Seattle Totems). The Seattle Totems had sued for antitrust violations after their application to join NHL was rejected twice by existing members of the league who were also defendants in this case. During pre-trial proceedings, it was found that NHL failed to comply with two court orders regarding document production which led to dismissal of their defense as sanction under Rule 37(b)(2)(C) of Federal Rules of Civil Procedure by lower courts including Court Of Appeals For The Ninth Circuit. However, on appeal at Supreme Court level, it ruled unanimously that while district courts have broad discretion in imposing discovery sanctions under Rule 37(b), they should be just and related to particular claim at hand instead being harsh or punitive; hence reversing decision made by lower courts about dismissing defendant's claims entirely due lack non-compliance during discovery phase.

In the dissenting opinion for the case of National Hockey League et al. v. Metropolitan Hockey Club, Inc., it was argued that there should be a more stringent standard applied to determine whether or not sanctions are appropriate in cases where discovery rules have been violated. The justice disagreed with the majority's decision to uphold lower courts' rulings that imposed severe penalties on NHL and its member clubs for failing to comply fully with discovery orders related to an antitrust suit brought by Metropolitan Hockey Club (Seattle Totems). He believed that such harsh punishment - dismissal of NHL's counterclaim and default judgment against them - was unwarranted given their substantial compliance with most aspects of those orders, as well as absence of any clear evidence showing they acted in bad faith or caused significant prejudice to Seattle Totems' ability to prepare its case. Instead, he suggested adopting a balancing test approach which would take into account various factors including seriousness and impact of non-compliance before deciding on suitable sanctions.