Service Employees International Union National Industry Pension Fund v. Scientific and Commercial Systems Corporation
249 F. Supp. 3d 130
| D.D.C. | 2017Background
- SEIU National Industry Pension Fund sued Scientific and Commercial Systems Corporation (SCSC) in 2013, alleging SCSC failed to pay ERISA withdrawal liability after cancelling its union contract following termination of a subcontract.
- SCSC filed a cross-claim against Tessada & Associates, Inc. (TAI) seeking indemnification for any liability to SEIU.
- The Court granted summary judgment to SEIU on SCSC’s liability for the withdrawal penalty.
- TAI entered bankruptcy and SCSC’s cross-claim against TAI remained unresolved; the Court stayed proceedings on that claim.
- SEIU moved under Federal Rule of Civil Procedure 54(b) to enter final judgment against SCSC so it could enforce the award without waiting for resolution of the TAI bankruptcy and related cross-claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the summary-judgment ruling is a "final judgment" under Rule 54(b) | The judgment on SEIU’s sole claim against SCSC is a final, separable adjudication enabling certification. | The ruling is not final because related claims (SCSC’s indemnity cross-claim against TAI) remain pending and SCSC’s liability may be affected. | The Court held the summary-judgment decision is final as to SEIU’s claim; remaining cross-claims among other parties do not defeat finality. |
| Whether there is "no just reason for delay" to enter final judgment under Rule 54(b) | Immediate entry serves justice: SEIU needs enforcement now; TAI’s bankruptcy will delay resolution; the adjudicated and unadjudicated claims are separable. | Certification would risk piecemeal appeals and duplicative litigation; cross-claims are intertwined and could affect enforcement. | The Court found Allis-Chalmers factors favor certification: claims are separable, appeal won’t be mooted by future events, no duplicative review, no set-off risk, and bankruptcy-related delay counsels for entry. |
Key Cases Cited
- Curtiss-Wright Corp. v. Gen. Elec. Co., 446 U.S. 1 (1980) (two-step Rule 54(b) framework: finality then no-just-reason inquiry)
- Allis-Chalmers Corp. v. Phila. Elec. Co., 521 F.2d 360 (3d Cir. 1975) (lists factors for evaluating whether there is no just reason for delay under Rule 54(b))
- Brooks v. Dist. Hosp. Partners, L.P., 606 F.3d 800 (D.C. Cir. 2010) (Rule 54(b) balances justice to litigants and sound judicial administration)
- Capital Transit Co. v. District of Columbia, 225 F.2d 38 (D.C. Cir. 1955) (holding that a single adjudicated claim in a multi-claim action can be final for Rule 54(b) purposes)
- Waldorf v. Shuta, 142 F.3d 601 (3d Cir. 1998) (approving certification where remaining claims would not cause appellate courts to relitigate decided issues)