Hall v. Hall
138 S. Ct. 1118
SCOTUS2018Background
- Ethlyn Hall sued her son Samuel (and his firm) over management of her property (the “trust case”); after Ethlyn died, Elsa Hall succeeded as trustee and plaintiff.
- Samuel filed a separate suit against Elsa in her individual capacity (the “individual case”) asserting claims that had been counterclaimed in the trust case.
- The District Court consolidated the trust and individual cases under Federal Rule of Civil Procedure 42(a) and tried them together before a single jury.
- The jury returned a verdict for Samuel in the individual case (later the District Court granted Elsa a new trial, reopening that judgment) and returned a verdict against Elsa in the trust case; judgment was entered in the trust case and Elsa appealed.
- Samuel moved to dismiss the appeal for lack of appellate jurisdiction, arguing that consolidation merged the cases so the trust-case judgment was not final while the individual case remained pending; the Third Circuit dismissed the appeal. The Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument (Elsa) | Defendant's Argument (Samuel) | Held |
|---|---|---|---|
| Whether a final judgment in one of several Rule 42(a)-consolidated actions is immediately appealable | A final judgment in the trust case is appealable; consolidation does not merge distinct cases or extinguish appeal rights | Consolidation merged the actions for all purposes, so a judgment in one constituent case is interlocutory until all consolidated matters are resolved | Court held that consolidation under Rule 42(a) does not merge cases; a final decision in one consolidated action is immediately appealable |
Key Cases Cited
- Gelboim v. Bank of Am. Corp., 574 U.S. _ (2015) (MDL context: a disposed constituent case in multidistrict litigation is immediately appealable)
- Johnson v. Manhattan Ry. Co., 289 U.S. 479 (1933) (consolidation is for convenience and does not merge suits or change parties’ rights)
- Mutual Life Ins. Co. v. Hillmon, 145 U.S. 285 (1892) (consolidated suits remain distinct; separate judgments and rights preserved)
- Rich v. Lambert, 53 U.S. 347 (1851) (consolidated admiralty causes are distinct for purposes of appeal)
- Stone v. United States, 167 U.S. 178 (1897) (respecting separation of constituent cases after consolidated trial)
- Arizona v. Manypenny, 451 U.S. 232 (1981) (any litigant with a final district-court judgment is entitled to appeal)