Innovation Ventures, Ltd. Liab. Co. v. Custom Nutrition Labs, Ltd. Liab. Co. - 912 F.3d 316 (6th Cir. 2018)

Rule:

Appellate courts have jurisdiction to hear appeals from all final decisions of the district courts. 28 U.S.C.S. § 1291. A decision is final for the purposes of § 1291 if it ends the litigation on the merits and leaves nothing for the court to do but execute the judgment. This firm finality principle is designed to guard against piecemeal appeals. There is also a long-standing rule that a party may not appeal a judgment to which it consented. Satisfaction of that rule is a requirement of § 1291. 

Facts:

Some years ago, Plaintiff Innovation Ventures (Innovation), manufacturer of 5-Hour Energy, settled a lawsuit with the now-defunct Custom Nutrition Laboratories (Custom Nutrition) by entering into a noncompete agreement. When Nutrition Science Laboratories (NSL) subsequently purchased Custom Nutrition's assets, it did not abide by the restrictive covenants in that noncompete agreement. Innovation initially sued Custom Nutrition, NSL, and Alan Jones, an officer of both Custom Nutrition and NSL, and later added a suit against a related company, Lily of the Desert (collectively, Defendants). After protracted litigation, Innovation was awarded nominal damages for its core breach of contract claim. 

Issue:

Was appellate jurisdiction proper under 28 U.S.C.S. § 1291 where it was irrelevant that Innovation won an award of nominal damages and Innovation’s intention to appeal pursuant to Raceway was known to the court and opposing parties?

Answer:

Yes.

Conclusion:

The court held that appellate jurisdiction was proper under 28 U.S.C.S. § 1291 where it was irrelevant that Innovation won an award of nominal damages and Innovation’s intention to appeal pursuant to Raceway was known to the court and opposing parties. The antitrust counterclaim was dismissed because it did not relate back to the original counterclaim. The Settlement Agreement did not bind the officer in his personal capacity where the officer's signature was labeled "President and CEO" and the Agreement was centrally concerned with business negotiations and did not explicitly provide for personal liability. The court found that the district court's conclusion that NSL was bound by § 5.c of the Settlement Agreement by virtue of its incorporation into the Asset Purchase Agreement was affirmed.