Managed Care Advisory Group, LLC v. Cigna Healthcare, Inc., 21-10247

CIGNA Healthcare filed an expedited motion asking the district court to enforce a class settlement and enjoin MCAG from pursuing relief at a final arbitration before Special Master Joseph Matthews.
CIGNA contended MCAG lacked standing to pursue class-member claims and that the settlement agreement barred the relief MCAG sought.
The district court denied CIGNA’s motion in a paperless order but expressly gave CIGNA "leave to argue" the standing and settlement-scope issues to the Special Master, deferring substantive rulings.
After CIGNA appealed the denial, this Court asked the parties to address appellate jurisdiction and MCAG moved to dismiss for lack of jurisdiction.
The panel held the district court’s order was neither a final decision under 28 U.S.C. § 1291 nor an appealable injunction under 28 U.S.C. § 1292(a)(1), and dismissed the appeal.
The court distinguished an earlier Eleventh Circuit decision enforcing arbitral summonses as final, explaining that here the district court did not dispose of all issues and instead deferred them to the Special Master.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Finality under § 1291	Order is final because district court refused to stay arbitration and thereby disassociated itself	Denial did not resolve CIGNA’s claims; court left issues for the Special Master	Not final — order left the status quo and did not dispose of the motion’s issues; no § 1291 jurisdiction
Appealability under § 1292(a)(1)	Denial was a refusal to grant an injunction to stop arbitration and enforce the settlement	Denial was a case-management/pretrial stay decision, not an injunction	Not an appealable injunction — order was procedural, did not have serious irreparable consequences, so no § 1292(a)(1) jurisdiction

Gulfstream Aerospace Corp. v. Mayacamas Corp., 485 U.S. 271 (1988) (final-decision rule — appealability requires ending the litigation on the merits)
Thomas v. Blue Cross & Blue Shield Ass'n, 594 F.3d 823 (11th Cir. 2010) (postjudgment order is final only if it disposes of all issues raised in the motion)
Abbott v. Perez, 138 S. Ct. 2305 (2018) (labels do not control; functional approach to whether an order is an injunction)
Carson v. American Brands, Inc., 450 U.S. 79 (1981) (orders with the practical effect of granting or denying injunctions should be treated as injunctions for jurisdictional purposes)
Switz. Cheese Ass'n, Inc. v. E. Horne's Mkt., Inc., 385 U.S. 23 (1966) (pretrial orders that do not touch the merits are not interlocutory injunctions under § 1292(a)(1))
Alabama v. U.S. Army Corps of Eng'rs, 424 F.3d 1117 (11th Cir. 2005) (narrow reading of § 1292(a)(1); injunction elements and substantive impact required)
Managed Care Advisory Grp., LLC v. CIGNA Healthcare, Inc., 939 F.3d 1145 (11th Cir. 2019) (distinguished — enforcement of arbitral summonses was final because the district court had disposed of all issues)