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