Background
Regina Coco LaRue brought civil claims against Diann Chase and several other defendants in the U.S. District Court for the District of Maryland. The district court dismissed LaRue’s claims and dismissed some, but not all, of the defendants’ counterclaims.
LaRue, proceeding pro se, appealed. Because some counterclaims remained unresolved, the Fourth Circuit considered whether the district court’s order was immediately appealable.
The Court’s Holding
The Fourth Circuit dismissed the appeal for lack of jurisdiction. It explained that its jurisdiction generally extends to final orders under 28 U.S.C. § 1291 and to certain interlocutory and collateral orders under 28 U.S.C. § 1292, Federal Rule of Civil Procedure 54(b), and the collateral-order doctrine.
The district court’s order was not final because it left some counterclaims pending, and it did not qualify as an appealable interlocutory or collateral order. The court therefore could not review the merits of LaRue’s appeal. It also dispensed with oral argument.
Key Takeaways
- An order resolving a plaintiff’s claims but leaving some counterclaims pending ordinarily is not a final, appealable order.
- A nonfinal order may be appealed only if an applicable statute, Rule 54(b), or the collateral-order doctrine permits immediate review.
- The Fourth Circuit dismissed the appeal solely for lack of appellate jurisdiction and did not decide the merits of LaRue’s claims.
Why It Matters
The decision underscores that litigants generally must wait until the district court has resolved all claims and counterclaims before appealing. When issues remain pending, an appellant must identify a valid basis for immediate appellate review, such as a proper Rule 54(b) certification or a recognized exception to the final-judgment rule.