Background

• Katherine Brown appealed a district court form order that statistically closed her employment case against MHC Stagecoach, LLC, in Clark County, Nevada.
• The underlying action alleged discriminatory treatment by Brown's supervisor and constructive termination; Brown pursued settlement discussions through counsel.
• Settlement negotiations occurred; Brown proposed$7,500 but she objected to language limiting disclosure, leading to counsel withdrawal.
• The district court granted MHC's motion to enforce a settlement and later to deposit settlement proceeds; neither order entered final judgment resolving Brown's claims.
• After those interim orders, the district court issued a form order statisically closing the case as a 'Stipulated Judgment,' which Brown challenged on appeal.
• This Court concluded it lacked jurisdiction to entertain Brown's appeal since the statistical-closure order was not a final, appealable judgment.

Issues

Key Cases Cited

• Valley Bank of Nev. v. Ginsburg, 110 Nev. 440, 874 P.2d 729 (1994) (finality hinges on dispositive effect, not labeling)
• Lee v. GNLV Corp., 116 Nev. 424, 996 P.2d 416 (2000) (final judgment requires dismissal or resolution of claims)
• Taylor Constr. Co. v. Hilton Hotels Corp., 100 Nev. 207, 678 P.2d 1152 (1984) (appeals limited to statutorily authorized judgments and orders)
• Morton Int'l, Inc. v. A.E. Staley Mfg. Co., 460 F.3d 470 (3d Cir. 2006) (clerical orders directing case closure do not become final by entry)
• Delgrosso v. Spang & Co., 903 F.2d 234 (3d Cir. 1990) (non-final interloctory orders lacking dismissal or disposition are not final)
• Resnick v. Valente, 97 Nev. 615, 637 P.2d 1205 (1981) (appeal from motion-to-enforce settlement possible only with final judgment)
• St. Louis Union Station Holdings, Inc. v. Discovery Channel Store, Inc., 272 S.W.3d 504 (Mo. Ct. App. 2008) (enforcement-of-settlement orders become final after judgment on settlement)