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George Washington Statue at Federal Hall

Hallv.Hall

CourtSupreme Court of the United States
Docket No.16-1150
DecidedMarch 27, 2018
Reporter584 U.S. 59
JudgesSupreme Court of the United States
Tags
CivilCivil ProcedureAppellate ProcedureFederal JurisdictionStatutory InterpretationReversalRemandLandmark Ruling
Case Summary

After several related lawsuits were consolidated in federal district court, one case reached a final judgment while the others remained unresolved. The question was whether the losing party could immediately appeal that judgment or had to wait until every consolidated action was finished. The Supreme Court held that consolidation under Federal Rule of Civil Procedure 42 does not merge separate lawsuits into a single action. Each constituent case retains its separate identity, and a final decision resolving one of those cases is immediately appealable even when the other consolidated cases continue. The Court grounded that conclusion in the rule’s text, its historical predecessor, longstanding federal practice, and the ordinary meaning of a final decision under federal appellate jurisdiction. It rejected the argument that the word “consolidate” silently changed that established understanding. The Court reversed the judgment of the Court of Appeals for the Third Circuit and remanded for further proceedings consistent with its opinion.

Opinion

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