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CANTRELL v. BRUNSWICK MAINE POLICE
2:23-cv-00283
D. Me.
May 19, 2025
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Background

  • Plaintiff Brice Cantrell, proceeding pro se, sued the Brunswick, Maine Police and related town entities and individuals, raising various civil rights claims.
  • Attorney Kristen Collins, a lawyer for the town, was named as a defendant.
  • The court found Cantrell's complaint contained no factual allegations against Collins, beyond her name and role.
  • Claims against Collins and others were dismissed under Rule 12(b)(6) for failure to state a claim.
  • Cantrell attempted to appeal the dismissal, but the First Circuit dismissed for lack of appellate jurisdiction as not all claims in the case were resolved.
  • Discovery proceeded on remaining claims; Collins sought entry of final judgment under Rule 54(b), which Cantrell did not oppose.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether dismissal of Collins was final as to her Not expressly argued Yes; all claims against her were resolved Yes; dismissal was final as to Collins
Whether there was just reason for delay of judgment Not expressly argued No; delay causes reputational harm, unfairness No just reason for delay; entry of final judgment ordered
Effect on judicial resources and fairness Not expressly argued Split judgment prevents continued harm/expense Entry promoted judicial efficiency, no overlap with others
Possible prejudice to plaintiff Implicitly prefers to appeal No prejudice; plaintiff wants immediate appeal Plaintiff not prejudiced by entry of final judgment

Key Cases Cited

  • Spiegel v. Trs. of Tufts Coll., 843 F.2d 38 (1st Cir. 1988) (explained policy against piecemeal appeals and entry of judgment)
  • Curtiss-Wright Corp. v. Gen. Elec. Co., 446 U.S. 1 (1980) (delineated the role of the district court when applying Rule 54(b))
  • Credit Francais Int'l, S.A. v. Bio-Vita, Ltd., 78 F.3d 698 (1st Cir. 1996) (outlined requirements for finality under Rule 54(b))
  • Nystedt v. Nigro, 700 F.3d 25 (1st Cir. 2012) (dismissal under Rule 12(b)(6) is final for Rule 54(b) purposes)
Read the full case

Case Details

Case Name: CANTRELL v. BRUNSWICK MAINE POLICE
Court Name: District Court, D. Maine
Date Published: May 19, 2025
Docket Number: 2:23-cv-00283
Court Abbreviation: D. Me.