Tiedel V. Northwestern Michigan College

In this diversity action plaintiff-appellant Michael Tiedel appeals from the final judgment awarding the defendant $47,753.01 in actual attorneys' fees and other litigation costs, pursuant to Local Rule 42(j) and (k) of the United States District Court for the Western District of Michigan. This appeal presents the question of whether a district court may enforce its pretrial mediation plan by taxing the losing party with the prevailing party's actual attorneys' fees pursuant solely to the authority of a local district rule. For the reasons set out below we hold it may not, and reverse.