Friday, December 6, 2013

Digital Equipment Corp. v. Desktop Direct, Inc. case brief

Digital Equipment Corp. v. Desktop Direct, Inc. case brief summary
511 U.S. 863 (1994)

CASE SYNOPSIS
Petitioner sought review of the decision of the United States Court of Appeals for the Tenth Circuit which dismissed petitioner's appeal of the lower court's holding that vacated dismissal and rescission of a settlement agreement and which held that the court order was not appealable under 28 U.S.C.S. § 1291 because it neither ended the litigation on the merits nor fell within the collateral order exception to the final judgment requirement.

CASE FACTS
Respondent trade name owner filed an action in district court charging petitioner with unlawful use of respondent's trade name. Petitioner agreed to pay respondent to use the trade name for waiver of all damages and dismissal of the suit. Respondent moved to vacate the dismissal and rescind the settlement agreement, alleging misrepresentation of material facts during settlement negotiations. The district court granted the motion. The court of appeals dismissed the appeal, holding that the court order was not appealable under 28 U.S.C.S. § 1291 because it neither ended the litigation on the merits nor fell within the long-recognized collateral order exception to the final judgment requirement.

DISCUSSION

  • On appeal from certiorari, the court concluded that despite petitioner's position that it held a right not to stand trial requiring protection by way of immediate appeal, the rights under private settlement agreements would be better vindicated on appeal from final judgment rather than a § 1291 collateral order appeal. 
  • The lower court's refusal to enforce the settlement agreement that was claimed to shelter petitioner from suit did not supply the basis for immediate appeal under § 1291.

CONCLUSION
The court affirmed the court of appeals' dismissal of petitioner's appeal because the refusal to enforce the settlement agreement that was claimed to shelter the parties from breach of contract did not supply the basis for immediate appeal under a collateral order appeal.

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