Meierhenry Sargent LLP v. Bradley Williams, 992 F.3d 661

Dispute arises from a fee agreement between Meierhenry Sargent LLP (the firm) and the Williamses over attorney fees and several counterclaims asserted by the Williamses in arbitration.
On prior appeal, this Court held several counterclaims non‑arbitrable, but left the Williamses’ breach‑of‑contract claim unaddressed.
On remand the firm asked the district court to limit arbitration: the breach‑of‑contract claim could be arbitrated only to the extent any damages would reduce fees owed to the firm.
The district court clarified its earlier order and enjoined arbitration of counterclaims seeking damages exceeding the fees claimed by the firm.
The Williamses appealed, challenging the clarification as an improper rewriting of the original order and raising three other interlocutory complaints (a now‑moot stay, a remark about arbitrator neutrality, and whether certain counterclaims were properly filed).
The panel affirmed the district court’s clarification under Rule 60(a), dismissed three other challenges for lack of appellate jurisdiction, and noted a concurrence casting doubt on whether an injunction against arbitration was permissible but recognizing law of the case.

Issue	Williamses' Argument	Meierhenry Sargent's Argument	Held
Whether the district court improperly rewrote its original order by enjoining arbitration of damages exceeding fees owed	The court exceeded its authority by restricting arbitration and effectively rewriting the prior order	The clarification merely applied the earlier ruling to the breach‑of‑contract claim and was within the court's authority to correct/clarify	Affirmed: clarification permissible under Fed. R. Civ. P. 60(a); no abuse of discretion
Whether the appeal can review a stay that has since expired	The stay decision was erroneous and reviewable	Conditions underlying stay have passed so no relief is available	Dismissed as moot; not within capable‑of‑repetition‑yet‑evading review
Whether the court’s offhand suggestion that arbitrators be neutral is reviewable	The remark prejudiced arbitration and is appealable	The remark is an interlocutory, nonfinal comment not subject to immediate review	Dismissed for lack of appellate jurisdiction (not a final or immediately appealable order)
Whether the Williamses properly filed several counterclaims and that should be reviewed now	Their filings were proper and the court erred in not treating them so	The issue is interlocutory and not within the courts’ immediate appellate jurisdiction	Dismissed for lack of jurisdiction (not a final or §16 interlocutory order)

Meierhenry Sargent LLP v. Williams, 915 F.3d 507 (8th Cir. 2019) (prior appeal resolving arbitrability of several counterclaims)
Hartis v. Chicago Title Ins. Co., 694 F.3d 935 (8th Cir. 2012) (district court may clarify omissions under Rule 60(a))
United States v. Mansion House Ctr. N. Redev. Co., 855 F.2d 524 (8th Cir. 1988) (clarification reviewed for abuse of discretion)
Video Tutorial Servs., Inc. v. MCI Telecomms. Corp., 79 F.3d 3 (2d Cir. 1996) (expired interlocutory stay is paradigmatic mootness)
Stevenson v. Blytheville Sch. Dist. No. 5, 762 F.3d 765 (8th Cir. 2014) (capable‑of‑repetition‑yet‑evading‑review standard)
Klay v. United Healthgroup, Inc., 376 F.3d 1092 (11th Cir. 2004) (questioning whether courts may enjoin arbitration as a standalone cause of action)