Johnson v. Ocwen Loan Servicing, L.L.C., 916 F.3d 505

Teresa Johnson sued Ocwen (servicer) and Wells Fargo (owner) after foreclosure efforts; she asserted five claims: two federal RESPA claims and three state Texas Debt Collection Act claims.
The district court granted summary judgment for Ocwen on both RESPA claims and two state claims, leaving one state debt-collection claim under Tex. Fin. Code § 392.301(a)(8) for further review.
On January 4, 2018 the district court entered a Rule 54(b) partial final judgment disposing of the four dismissed claims, while one state claim remained pending.
The remaining state claim was resolved by summary judgment on January 31, 2018; Johnson filed a notice of appeal on March 1, after the 30-day appeal period for the Rule 54(b) judgment had expired but within 30 days of the final judgment.
The central disputes: whether Johnson’s late appeal of the Rule 54(b) judgment bars review of those dismissals in the later appeal; whether the Rule 54(b) entry was procedurally valid; and whether the final-judgment state claim was correctly decided on causation/damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether appeal of Rule 54(b) partial judgment is timely when not filed within 30 days of that partial judgment	Johnson contends the Rule 54(b) was unauthorized, so its separate appeal clock should not apply	Defendants argue the Rule 54(b) judgment started the appeal clock and Johnson missed it, barring review of those rulings	Court: Appeal of the federal claims dismissed by the Rule 54(b) judgment is untimely; lack of jurisdiction to hear them
2. Whether the Rule 54(b) judgment was unauthorized because only one "claim" existed	Johnson: She brought a single claim, so Rule 54(b) inapplicable	Defendants: Multiple distinct causes (RESPA vs. state debt-collection claims) constitute separate claims	Court: Multiple claims existed; Rule 54(b) threshold met
3. Whether the district court erred by not explaining "no just reason for delay"	Johnson: Court failed to state reasons, making the partial judgment defective	Defendants: Explanation not required; entry was proper	Court: No requirement to provide a statement of reasons; no defect shown
4. Merits of the remaining state claim on causation/damages	Johnson: She suffered emotional distress and time loss from defendants’ letters	Defendants: Causation not established as damages not tied to the challenged letters	Court: Summary judgment for defendants affirmed; Johnson failed to link damages to the April 2016 letters

Dickinson v. Petroleum Conversion Corp., 338 U.S. 507 (U.S. 1950) (explaining purpose of Rule 54(b) to avoid delay and injustice)
Smith v. Mine Safety Appliances Co., 691 F.2d 724 (5th Cir. 1982) (Rule 54(b) partial judgments start a separate appeal clock)
Bowles v. Russell, 551 U.S. 205 (U.S. 2007) (appeal periods are mandatory and jurisdictional)
Granack v. Continental Cas. Co., 977 F.2d 1143 (7th Cir. 1992) (partial judgment lacking "no just reason" may be defective)
Page v. Preisser, 585 F.2d 336 (8th Cir. 1978) (Permitting collateral attack on mischaracterized single-claim Rule 54(b) entries)
Tubos de Acero de Mexico, S.A. v. Am. Intern. Inv. Corp., 292 F.3d 471 (5th Cir. 2002) (tests for what constitutes separate claims under Rule 54(b))
Samaad v. City of Dallas, 940 F.2d 925 (5th Cir. 1991) (whether recovery on one claim bars recovery on another for Rule 54(b) analysis)
Rothenberg v. Sec. Mgmt. Co., 617 F.2d 1149 (5th Cir. 1980) (no absolute requirement that district court explain "no just reason for delay")
Allis-Chalmers Corp. v. Philadelphia Elec. Co., 521 F.2d 360 (3d Cir. 1975) (earlier Third Circuit decision on requiring statement of reasons)
Elliott v. Archdiocese of New York, 682 F.3d 213 (3d Cir. 2012) (clarifying that statement of reasons is prophylactic, not jurisdictional)
Christiana Trust v. Riddle, 911 F.3d 799 (5th Cir. 2018) (RESPA duties at issue do not impose vicarious liability)