Charvette Williams v. County of Dakota
2012 U.S. App. LEXIS 16273
| 8th Cir. | 2012Background
- Charvette Williams sued Dakota County, Nebraska and Deputy Herron for Title VII, sexual harassment, and Equal Pay Act claims.
- The County offered a limited Rule 68 settlement of 2,439.20 plus interest for the discriminatory pay claims (Counts 1 and 4); Williams accepted.
- Remaining claims (Counts 2 and 3) continued, involving harassment and hostile work environment.
- District court reduced Williams’s requested attorney’s fees (88.4 hours at $350, adjusted to $250) and later added $2,500 for response to objections.
- Two orders awarding fees were entered as final judgments under Rule 54(b) to permit interlocutory appeal, per the district court’s certification.
- Defendants appealed, challenging the district court’s Rule 54(b) certification and the fee award, arguing abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 54(b) certification was proper | Williams supported certification to allow appeal of the fee issue. | Dakota County contends certification was improper and an abuse of discretion. | 54(b) certification was an abuse of discretion; no jurisdiction to reach merits. |
| Whether the court had jurisdiction to review the attorney’s fees appeal | Certification created appellate jurisdiction over the fee awards. | No jurisdiction via waiver; certification was insufficient to confer jurisdiction. | Court lacked jurisdiction to review the fee awards on appeal. |
Key Cases Cited
- Outdoor Cent., Inc. v. GreatLodge.com, Inc., 643 F.3d 1115 (8th Cir. 2011) (jurisdiction under Rule 54(b) depends on final judgments and no just reason for delay)
- Clark v. Baka, 593 F.3d 712 (8th Cir. 2010) (standard for evaluating Rule 54(b) certification; deference to district court)
- Hayden v. McDonald, 719 F.2d 266 (8th Cir. 1983) (no just reason for delay required for 54(b) certification)
- Huggins v. FedEx Ground Package Sys., Inc., 566 F.3d 771 (8th Cir. 2009) (courts scrutinize 54(b) decisions when justification is not clear)
- Clos v. Corr. Corp. of Am., 597 F.3d 925 (8th Cir. 2010) (absence of reasoned analysis undermines certification decision)
- Little Earth of United Tribes, Inc. v. United States Dep’t of Hous. & Urban Dev., 738 F.2d 310 (8th Cir. 1984) (importance of analyzing factors in 54(b) determinations)