Ray Haluch Gravel Co. v. Cent. Pension Fund of the Int'l Union of Operating Eng'rs & Participating Emp'rs
134 S. Ct. 773
| SCOTUS | 2014Background
- Funds sue Haluch for unpaid ERISA/LMRA contributions and seek attorney’s fees and costs under ERISA §502(g)(2)(D) and the CBA.
- District Court awards partial merits in favor of Funds and later awards attorney’s fees and costs; judgment on the merits totals $26,897.41 with fees $34,688.15.
- Funds file fee petition; District Court allows submission with merits findings or later; Funds initially file with merits but later request extension for fees.
- June 17, 2011 memo order resolves merits but leaves fee issue unresolved; July 25, 2011 order finally awards fees and costs.
- Funds appeal August 15, 2011; Haluch argues June 17 order was final and untimely for §1291 appeal; Funds argue July 25 order governs finality.
- Court of Appeals holds June 17 order not final due to contract-based fee provision; certiorari granted to resolve finality question.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the June 17 merits order was a final decision for §1291. | Funds rely on Budinich to treat unresolved fees as nonfinal. | Haluch asserts a single merits judgment; fees do not block finality. | Yes; June 17 is final for §1291 purposes. |
| Does a contract-based fee claim affect finality differently from a statute-based claim? | Funds contend contract-based fees are part of damages, delaying finality. | Haluch contends uniform finality rule applies regardless of fee source. | No difference; uniform rule applies; fee unresolved does not defeat finality. |
| Does Budinich extend to prelitigation (pre-complaint) fees incurred for the case? | Fees accrued before filing are excluded from Budinich's scope. | Pre-filing tasks may be part of the litigation and recoverable. | Pre-litigation fees may be included; they are part of the litigation. |
| Do procedural rules (Rule 54(d)(2), Rule 58(e)) permit delaying appeal to resolve fees? | Rule 54(d)(2) can consolidate fee issues without delaying finality. | Rules support delaying only where appropriate; finality should be prompt. | Rules support treating fees as collateral; finality remains intact. |
| Are auditor’s/related nonattorney fees recoverable and treated the same as attorney’s fees for finality? | Auditor’s fees accompany the fee request; may be treated differently. | Such fees are incidental to the fee award and should follow Budinich. | Incidental nonattorney fees fall within the Budinich approach. |
Key Cases Cited
- Budinich v. Becton Dickinson & Co., 486 U.S. 196 (1988) (unresolved attorney’s fees do not prevent final merits judgment)
- Webb v. Dyer County Bd. of Educ., 471 U.S. 234 (1985) (pre-filing tasks may be part of the litigation)
- Digital Equipment Corp. v. Desktop Direct, Inc., 511 U.S. 863 (1994) (clarifies finality and piecemeal appeals in fee contexts)
- Bowles v. Russell, 551 U.S. 205 (2007) (jurisdictional time requirements are strict)
- Catlin v. United States, 324 U.S. 229 (1945) (finality generally ends merits litigation; nothing remains except judgment)
- West Virginia Univ. Hospitals, Inc. v. Casey, 499 U.S. 83 (1991) (fees sometimes characterize as costs on appeal)
- Continental Bank, N.A. v. Everett, 964 F.2d 701 (1992) (circuit-level discussion of finality and fee awards)