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APPELLATE REVIEW
I will distribute hard copy tomorrow.
CIVIL PROCEDURE
G. VAIRO
APPELLATE REVIEW
APPELLATE REVIEW assignment: Read 1009-1011; 1025-26; 1035-36; 1045-46; 1049-1052. Also read 28 USC sections 1291; 1292; Rule 23(f); 28 USC 1453(c); 1253; 1254; 1257. Also, read and take a stab at responding to the hypothetical problem at 1090.
I. Review in the trial court: When a party loses a motion, or a trial, it generally will be unhappy. Is there a procedure to help it out at the trial court level?
A. Motion for Reconsideration: If the party has lost a motion, it may make a motion for reconsideration before the court that ruled on the losing motion. The following is a typical standard for making a motion for consideration:
A motion for reconsideration pursuant to Local Rule 6.3 will be granted if the moving party presents factual matters or controlling decisions the court overlooked that might materially have influenced its decision. Pereira v. Aetna Casualty and Surety Co. (In re Payroll Express Corp.), 921 F.Supp. 1121, 1123 (S.D.N.Y. 1996); Violette v. Armonk Assocs., L.P., 823 F.Supp. 224, 226 (S.D.N.Y. 1993). Reconsideration is also appropriate in light of an intervening change of controlling law, the availability of new evidence, or the need to correct a clear error or prevent manifest injustice. Doe v. New York City Dep't of Social Servs., 709 F.2d 782, 789 (2d Cir. 1983); Casino, LLC v. M/V Royal Empress, 1998 WL 566772, at *1 (E.D.N.Y. 1998). Local Rule 6.3 is to be narrowly construed and strictly applied so as to avoid repetitive arguments on issues that have been fully considered by the court. See Caleb & Co. v. E.I. Du Pont De Nemours & Co., 624 F.Supp. 747, 748 (S.D.N.Y. 1985). In deciding a Local Rule 6.3 motion, the court will not allow a party to use the motion as a substitute for appealing from a final judgment. See Morser v. A.T. & T. Information Systems, 715 F.Supp. 516, 517 (S.D.N.Y. 1989); Korwek v. Hunt, 649 F.Supp. 1547, 1548 (S.D.N.Y. 1986). Therefore, a party in its motion for reconsideration "may not advance new facts, issues or arguments not previously presented to the court." Litton Indus., Inc. v. Lehman Bros. Kuhn Loeb, Inc., 1989 WL 162315, at *3 (S.D.N.Y. 1989).
Note: There is no FRCP for making a motion for reconsideration. However, most federal district courts (and state courts) provide parties with a tool for making a motion for reconsideration. Additionally, the standard for granting the motion, as you see above, is quite high. Such motions are rarely granted.
B. Post-trial Motions: If the party has lost a trial, there are various post-trial motions that can be made, pursuant to the FRCP. As we saw when we discussed the Gasperini case, a party may move for a new trial under Rule 59. A party also may make a motion for judgment as a matter of law under Rule 50. You are not responsible for knowing the nuts and bolts of these rules. However, please keep in mind that when you get into practice you must know these rules. It is very easy to make a mistake by not making a motion at the correct time. If you fail to comply with the technical rules for making such motions, your motion will not be granted.
C. Motion for Relief from Judgment or Order: Finally, if judgment has been entered, as have discussed in class, a party may make a motion to reopen the judgment under Rule 60 under Rule 60(a) when there has been a clerical error (for example, the clerk entered the judgment as $1,000,000 when the actual jury verdict is for $100,000)); or, under Rule 60(b) on the grounds of mistake, inadvertence, excusable neglect, newly discovered evidence, fraud, etc.
II. Appealability:
A. Federal Rules of Appellate Procedure: Your rules supplement contains the Federal Rules of Appellate Procedure. Like the FRCP, they were enacted pursuant to the Rules Enabling Act, 28 U.S.C. § 2072. You are not responsible for knowing them now. Like the post-trial rules, it is very easy to make a mistake, and not file an appeal at the right time. The appellate timing rules in the FRAP are jurisdictional in nature. Thus, if you make a mistake, you are out of luck.
B. Final Decisions v. Interlocutory Orders:
In federal courts, one must make a distinction between final judgments and orders, on the one hand, and interlocutory orders, on the other. The key provision with respect to federal appellate review is 28 U.S.C. § 1291. It provides appellate jurisdiction only over “final decisions” of the federal district courts. A final decision is the order that results in the termination of the case. Typically, the final decision is the piece of paper called a “Judgment” that is entered after a successful motion to dismiss; or summary judgment; or after a trial. As a corollary, there is no federal appellate jurisdiction under § 1291 of interlocutory orders, such a the judge’s decision denying a motion to dismiss or for summary judgment. Denial of the motion means that the case will go on. Similarly, a decision denying a motion to compel arbitration is not final – the case will go on. Any decision in a discovery dispute is interlocutory, and thus non-final for appeal purposes, unless it is a dismissal or default order as a discovery sanction under FRCP 37.
The policy underlying the general federal rule favoring review only of final decisions is that to avoid piecemeal appeals. Also, the number of appeals is likely to be less because the longer one is required to wait, the greater the likelihood of settlement, which will obviate the need for any appeal.
Note that state courts, including California state courts, may have different rules. New York allows for interlocutory appeal of many issues. California, as you know, REQUIRES an immediate “appeal” of a trial court decision denying a motion to quash for lack of personal jurisdiction. California’s policy is to have immediate review to ensure that the lower courts are not burdened with cases that should not be litigated in the state.
C. Exceptions:
Of course, there are exceptions to the federal final judgment rule.
1. The Collateral Order Doctrine – Actually a “practical construction of 1291” -- Derived from a line of Supreme Court cases. This doctrine holds that there are certain interlocutory decisions are “effectively” final. For example, in the Cohen case, the Court held that a district court decision refusing to require the plaintiff to post a bond required by statute was effectively final for appellate review purposes. The defendant had a statutory right to the posting of a bond. The Court distinguished between the typical interlocutory order as one that is simply a step on the way to resolution, and the one before it: here, the Court said that the right to the bond posting “falls in that small class that finally determine claims separable from, and collateral to, rights asserted in the action, too important to be denied review and too independent from the cause itself to require that appellate consideration be deferred . . . . If the right [to the posting] were clear and the order involved only an exercise of discretion . . . appealability would present a different question.” Other examples: grant or denial of a disqualification of an attorney based on conflict of interest or other grounds; grant of a motion to disqualify a trial judge; order of interim attorney’s fees in civil rights case.
2. 28 U.S.C. § 1292
a) 1292(a)(1) – Interlocutory orders granting, continuing, modifying, refusing or dissolving injunctions, or refusing to dissolve or modify injunctions, are appealable.
b) 1292(b) – Discretionary: When the district judge certifies that the order contains a controlling question of law as to which there are substantial grounds for difference of opinion where the immediate appeal of such order will materially advance the ultimate termination of the litigation, the court of appeals may, in its discretion, permit the appeal.
3. FRCP 23(f) – Discretionary: A court of appeals may permit an appeal of a district court order granting or denying class action certification.
4. 28 U.S.C. § 1453(c) – Discretionary: Unlike an order remanding an individual case to state court, under § 1453(c), any party seeking immediate review of a district court order granting or refusing to grant a motion to remand may appeal such ruling to the court of appeals.
5. FRCP 54(b) – Discretionary: In a multiparty/multiclaim litigation, sometimes the district court will dismiss all claims against one or more parties, or one or more claims against one or more parties. Rule 54(b) allows the district judge to
6. Mandamus – Under the All Writs Act, 28 U.S.C. § 1651, a party who seeks immediate review may petition the court of appeals for a writ of mandamus ordering the district court judge to reverse its ruling. For example, a party may petition the court of appeals to order the district court to reverse an order compelling discovery. The standard for obtaining a writ of mandamus is quite high. The petitioner must show that the district court far exceeded its jurisdiction and authority in rendering the order. A writ of mandamus was issued against a trial judge who essentially turned over the trial of a complex case to a special master.
7. Contempt – When a party or an attorney violate or refuse to comply with an otherwise non-appealable order, and is held in contempt, the contempt order is immediately appealable.
III. Standards of Review:
A. Issues of law – During the course of a litigation, many issues will arise. If the issue turns on a pure question of law, the court of appeals gets to take a fresh look – i.e., engage in a de novo review of the legal question. An example of a pure question of law is whether the district court applied the correct legal standard. Or, whether the standard was applied correctly. Keep in mind, however, that the district court has discretion when making many of its decisions. Many of these issues look like pure questions of law, but in reality are within the discretion of the court. For example, a purely legal question would be whether a district court must remand a case if the case could not have been brought in federal court in the first place. A discretionary issue would be whether the district court was correct in allowing discovery on the jurisdictional issue.
B. Findings of fact – Depends on the trier of fact, but always harder to have set aside than issues of law.
1. Jury Trial – Jury verdicts are rarely disturbed. The district court and court of appeals would have to find that there was a lack of competent proof on an essential element of the case.
2. Trial by Judge – Under FRCP 52(a), a district court’s fact findings may not be set aside unless they are “clearly erroneous.”
C. Mixed questions of law and fact – Generally treated as legal questions, thus subject to the degree of review set forth in “A”, above.
D. Keep in mind that most district court rulings during the course of a litigation – whether a counterclaim is compulsory or not, whether certain discovery may be had, etc., are discretionary, and subject to the abuse of discretion standard.
IV. Supreme Court Review:
A. Appeal as of right – 28 U.S.C. § 1253 – very limited: only three judge court rulings.
B. Certiorari – 28 U.S.C. § 1254 (rulings of courts of appeals) & 28 U.S.C. § 1257 (rulings of the highest court of the state in which the validity of federal law is called into question)
Posted by Professor Vairo on April 26, 2006 02:39 PM|Permalink
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