Parties may only appeal a final decision of a district court. 28 U.S.C.S. § 1295. A final judgment is defined as a decision by the district court that ends the litigation on the merits and leaves nothing for the court to do but execute the judgment. By requiring parties to raise all claims of error in a single appeal following final judgment on the merits, § 1295, like its counterpart 28 U.S.C.S. § 1291, forbids piecemeal disposition on appeal of what for practical purposes is a single controversy. If a case is not fully adjudicated as to all claims for all parties and there is no express determination that there is no just reason for delay or express direction for entry of judgment as to fewer than all of the parties or claims, there is no "final decision" under 28 U.S.C.S. § 1295(a)(1) and therefore no jurisdiction.
Appellant individual brought this action alleging patent infringement. The company filed a counterclaim seeking a declaratory judgment of invalidity and unenforceability. The district court granted the companies' motion for summary judgment as to the invalidity of some, but not all, claims, and denied the individual's motion for sanctions. The district court stayed the remainder of the company's counterclaim as to the other claims. On appeal, the court dismissed the action for lack of jurisdiction.
Did the district court render final judgment thereby giving the appellate court jurisdiction over the case?
The district court had several options available to enable the parties to appeal, including the entry of a judgment under Fed. R. Civ. P. 54(b) or 28 U.S.C.S. § 1292(b), (c)(1). However, the trial court kept the invalidity and unenforceability counterclaim as to the remaining claims pending appeal. Because a stayed order was not generally final for purposes of 28 U.S.C.S. § 1295(a)(1), the court lacked jurisdiction to hear the appeal.