Friday, December 27, 2013

Cunningham v. Hamilton County case brief

Cunningham v. Hamilton County case brief summary
527 U.S. 198 (1999)

CASE SYNOPSIS
Petitioner attorney sought review from the United States District Court of Appeals for the Sixth Circuit, which dismissed her appeal of an order imposing sanctions pursuant to Fed. R. Civ. P. 37(a)(4), for lack of jurisdiction because it was not a final order under 28 U.S.C.S. § 1291.

CASE FACTS
Petitioner was an attorney representing a client in a federal civil rights action filed against respondent county and others. After failing to heed a magistrate's orders pertaining to discovery, respondents filed motions for sanctions against petitioner. The magistrate found that petitioner had violated the discovery order and imposed sanctions pursuant to Fed. R. Civ. P. 37(a)(4). Following the trial court's affirmance of the magistrate's sanctions order, petitioner immediately appealed. The court of appeals dismissed petitioner's appeal for lack of jurisdiction.

DISCUSSION

  • On appeal, the Court affirmed the decision dismissing petitioner's appeal for lack of jurisdiction because a sanctions order imposed on an attorney was not a final decision under 28 U.S.C.S. § 1291. 
  • An attorney's continued participation in a case did not affect whether a sanctions order was final for purposes of § 1291. 
  • To permit an immediate appeal of sanctions would undermine the purposes of Fed. R. Civ. P. 37(a).
CONCLUSION
The Court affirmed the dismissal of petitioner attorney's appeal of an order imposing sanctions for lack of jurisdiction because a sanctions order imposed on an attorney was not a final decision.

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