Background
Alexsam, Inc. sued Simon Property Group, L.P. for allegedly infringing a patent covering systems used with multifunction cards, including prepaid gift cards. Simon filed a state-law third-party complaint against Blackhawk Network, Inc., alleging that Blackhawk had supplied the accused cards and was contractually obligated to defend and indemnify Simon, including for attorneys’ fees.
After granting summary judgment of noninfringement, the district court entered an amended final judgment denying as moot all unresolved counterclaims, other claims, and motions. Simon promptly moved to clarify that its indemnification claim remained unresolved, styling its request under Rules 54(b) and 60(a). The district court later ruled that the indemnification claim had been dismissed as moot, although without prejudice, and Simon appealed that ruling.
The Court’s Holding
The Federal Circuit held that Simon’s motion was properly treated according to its substance as a Rule 60(b)(1) motion, despite its Rule 60(a) label. Because Rule 60(b)(1) covers judicial mistakes of law and Simon filed the motion within the time for an appeal, the motion was an available means to challenge the dismissal.
The court further held that the indemnification dispute was not moot because Simon and Blackhawk continued to dispute Simon’s right to indemnification. Dismissing the claim as moot was therefore legal error, and denying Rule 60(b)(1) relief was an abuse of discretion. Based on the parties’ agreement that dismissal on supplemental-jurisdiction grounds was appropriate, the Federal Circuit vacated the challenged order and remanded with instructions to dismiss the indemnification claim without prejudice under 28 U.S.C. § 1367(c), without deciding whether the governing discretionary-dismissal factors otherwise were satisfied.
Key Takeaways
- A court evaluates a postjudgment motion by its substance rather than the rule cited in its title.
- Rule 60(b)(1) can remedy a judge’s legal error, and Simon’s timely motion properly challenged the mistaken mootness dismissal.
- An unresolved contractual indemnification dispute does not become moot merely because the underlying patent claims have been resolved.
- The indemnification claim must be dismissed without prejudice under 28 U.S.C. § 1367(c), rather than dismissed as moot.
Why It Matters
The nonprecedential decision illustrates how parties may obtain timely postjudgment relief when broad language in a final judgment mistakenly disposes of a still-live claim. It also distinguishes a constitutional mootness dismissal from a discretionary decision to decline supplemental jurisdiction over a state-law claim.
For litigants pursuing contractual indemnification alongside federal patent claims, the ruling underscores the importance of promptly addressing any judgment that appears to dispose of the indemnification dispute without resolving its merits.