Mindy Carpenter v. Liberty Ins. Corp.

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 15, 2021
Docket20-3465
StatusUnpublished

This text of Mindy Carpenter v. Liberty Ins. Corp. (Mindy Carpenter v. Liberty Ins. Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mindy Carpenter v. Liberty Ins. Corp., (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0135n.06

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED ) Mar 15, 2021 MINDY CARPENTER and SHAWN ) DEBORAH S. HUNT, Clerk CARPENTER, ) ) ON APPEAL FROM THE UNITED Plaintiffs-Appellants, ) STATES DISTRICT COURT FOR ) THE SOUTHERN DISTRICT OF v. ) OHIO ) LIBERTY INSURANCE CORPORATION, ) ) Defendant-Appellee. )

BEFORE: SILER, WHITE, and STRANCH, Circuit Judges.

SILER, Circuit Judge. After a series of rulings that left one of Plaintiffs’ claims pending

for trial, the district court granted Plaintiffs’ request for an immediate appeal pursuant to Fed. R.

Civ. P. 54(b). Because we find that the district court improvidently granted Fed. R. Civ. P. 54(b)

certification, we DISMISS this appeal WITHOUT PREJUDICE.

FACTUAL AND PROCEDURAL HISTORY

In 2016, fire damaged the home of Plaintiffs Mindy and Shawn Carpenter. Defendant

Liberty Insurance Corporation (Liberty) insured the Carpenters’ home for fire damage. After

Liberty denied the Carpenters’ insurance claim, stating that it had reason to believe the Carpenters

started the fire, the Carpenters brought this action. The Carpenters assert two claims—breach of

insurance contract and bad faith insurance claim denial—and additionally seek “severe emotional

distress/inconvenience/punitive damages[.]” Case No. 20-3465, Carpenter, et al. v. Liberty Ins. Co.

Liberty moved for partial summary judgment, seeking to limit the Carpenters’ potential

recovery on their breach of contract claim to the insurance policy amount and to prohibit the

Carpenters from recovering emotional distress damages arising from that claim. The district court

granted the motion, but noted that damages for emotional distress, attorney fees, and punitive

damages could be recoverable under the bad faith claim. Later, Liberty moved for summary

judgment on the Carpenters’ bad faith insurance denial claim. The district court granted this

motion as well, eliminating all damages other than those set forth in the policy. After granting the

second motion, the district court certified its damages and bad faith insurance denial claim rulings

for immediate appeal under Fed. R. Civ. P. 54(b).

DISCUSSION

“The courts of appeals . . . shall have jurisdiction of appeals from all final decisions of the

district courts of the United States . . . .” 28 U.S.C. § 1291 (emphasis added). “[A] ‘final decision’

is one that ends the litigation on the merits and leaves nothing for the court to do but execute the

judgment.” Ray Haluch Gravel Co. v. Cent. Pension Fund of Intern. Union of Operating Eng’rs

and Participating Emps., 571 U.S. 177, 183 (2014) (citing Catlin v. United States, 324 U.S. 229,

233 (1945)).

Both parties agree that this case is properly before this court. That being said, “[t]hough

not raised by the parties, [when] a substantial question exists about the propriety of using Rule

54(b) to present [an] issue to the Court[,] ‘[b]ecause it involves the scope of our appellate

jurisdiction, we are compelled to raise sua sponte the issue of whether the district court’s entry of

final judgment was warranted.’” Justice v. Pendleton Place Apartments, 40 F.3d 139, 141 (6th

Cir. 1994) (quoting Braswell Shipyards, Inc. v. Beazer E., Inc., 2 F.3d 1331, 1336 (4th Cir. 1993));

see also Daleure v. Commonwealth of Ky., 269 F.3d 540, 543 (6th Cir. 2001) (“While all parties

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seek to confer appellate jurisdiction, we must dismiss the appeal . . . because we lack appellate

jurisdiction. . . . The district court has not entered final judgment on most claims, and could not,

because it had not ruled on the injunctive aspects of [certain] claims. In addition, its certification

of appealability under Rule 54(b) did not contain the findings required under Sixth Circuit

precedent.”).

As noted, we have jurisdiction under 28 U.S.C. § 1291 to review final orders of the district

court. Usually, “when a district court grants summary judgment on some but not all claims” in a

lawsuit, “the decision is not a final order for appellate purposes.” Planned Parenthood Sw. Ohio

Region v. DeWine, 696 F.3d 490, 500 (6th Cir. 2012). But under Federal Rule of Civil Procedure

54(b), the district court may certify a partial grant of summary judgment for immediate appeal if

the court “expressly determines that there is no just reason for delay.” Fed. R. Civ. P. 54(b). Rule

54(b) recognizes the “‘reality that the benefits of immediate appeals on occasion exceed the

costs,’” In re Fifth Third Early Access Cash Advance Litig., 925 F.3d 265, 273 (6th Cir. 2019)

(quoting Adler v. Elk Glenn, LLC, 758 F.3d 737, 739 (6th Cir. 2014) (Sutton, J., concurring)),

justifying occasional departures from the general federal policy disfavoring piecemeal appeals.

Corrosioneering, Inc. v. Thyssen Env’t Sys., Inc., 807 F.2d 1279 (6th Cir. 1986), outlines

the purpose and function of Fed. R. Civ. P. 54(b):

Rule 54(b) was a response to the need created by the liberal joinder provisions of the Federal Rules of Civil Procedure to revise “what should be treated as a judicial unit for purposes of appellate jurisdiction.” The rule was “designed to facilitate the entry of judgment on one or more claims, or as to one or more parties, in a multi- claim/multi-party action,” “where the parties demonstrated a need for making review available on some of the claims or parties before entry of final judgment as to all.” It “attempts to strike a balance between the undesirability of piecemeal appeals and the need for making review available at a time that best serves the needs of the parties.” By utilizing Rule 54(b), a district court “may, by the exercise of its

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discretion in the interest of sound judicial administration, release for appeal final decisions upon one or more, but less than all, claims . . . .”

Id. at 1282 (citations omitted) (emphasis in original).

“Proper certification under Rule 54(b) is a two-step process.” Planned Parenthood,

696 F.3d at 500.

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Mindy Carpenter v. Liberty Ins. Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mindy-carpenter-v-liberty-ins-corp-ca6-2021.