Paracha v. Bush, Civil Action No. 2004-2022

Petitioner Saifullah Paracha previously moved for summary judgment arguing certain Acts of Congress (or sections) were bills of attainder; the Court denied that motion on June 16, 2016 for lack of standing as to that claim.
Paracha then moved under Fed. R. Civ. P. 54(b) for entry of final judgment on the bill-of-attainder claim to allow immediate appeal, while his habeas petition remained pending.
The government opposed, arguing Paracha’s motion was conclusory and failed to show why an immediate appeal should proceed rather than waiting for resolution of all claims.
The Court found the bill-of-attainder claim completely separate from the habeas petition: resolving it would not affect Paracha’s detention or transfer and involves different legal issues.
The Court also noted the habeas petition has been pending since 2004 and had been stayed at Paracha’s request, so further delay before appeal could be substantial.
The Court concluded there is no just reason to delay and granted Rule 54(b) judgment, allowing an immediate appeal of the bill-of-attainder ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 54(b) certification appropriate for the bill-of-attainder claim	Paracha: the bill-of-attainder claim is unrelated and independent of his habeas petition, so final judgment should be entered for immediate appeal	Government: Paracha’s showing is conclusory and does not explain why an appeal should proceed before resolution of all claims; therefore they do not consent	Court: Granted Rule 54(b) certification — claim is severable and unrelated to habeas, so no just reason to delay appeal
Whether adjudicating the bill-of-attainder claim now would cause duplicative or inefficient appellate proceedings	Paracha: immediate appeal is warranted because the claim involves distinct legal issues that won’t affect detention	Government: implied concern that piecemeal appeals waste resources and should be avoided absent strong reasons	Court: Found no risk of duplicative appellate decisions because issues are distinct; judicial-administrative concerns and equities favor immediate appeal

United States v. All Assets Held in Account No. XXXXXXXX, 314 F.R.D. 12 (D.D.C. 2015) (discussing requirement that district court dispose of all claims before appeal absent Rule 54(b))
Capitol Sprinkler Inspection, Inc. v. Guest Servs., Inc., 630 F.3d 217 (D.C. Cir. 2011) (same principle on finality of district court orders)
Cincinnati Ins. Co. v. All Plumbing, Inc., 812 F.3d 153 (D.C. Cir. 2016) (policy reasons against piecemeal appeals and need to protect district court’s administration)
Blue v. Dist. of Columbia Pub. Sch., 764 F.3d 11 (D.C. Cir. 2014) (same)
Detroit Int’l Bridge Co. v. Gov’t of Canada, 53 F. Supp. 3d 28 (D.D.C. 2015) (noting Court of Appeals lacks jurisdiction without explicit Rule 54(b) finding)
Blackman v. Dist. of Columbia, 456 F.3d 167 (D.C. Cir. 2006) (jurisdictional requirement for Rule 54(b) certification)
Curtiss-Wright Corp. v. Gen. Elec. Co., 446 U.S. 1 (1980) (factors for deciding whether there is no just reason to delay under Rule 54(b))
Brooks v. Dist. Hosp. Partners, L.P., 606 F.3d 800 (D.C. Cir. 2010) (Rule 54(b) and factors to consider)
Taylor v. F.D.I.C., 132 F.3d 753 (D.C. Cir. 1997) (district courts should supply statement of reasons when ruling on Rule 54(b) motions)