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Keywords

lawsuitjurisdictionappealrespondent

jurisdictionappealrespondent

Related Cases

Richardson-Merrell, Inc. v. Koller, 472 U.S. 424, 105 S.Ct. 2757, 86 L.Ed.2d 340, 53 USLW 4773

Facts

Respondent Anne Koller was born with severe birth defects and filed a lawsuit against Richardson-Merrell, Inc., claiming that her mother took Bendectin during pregnancy, causing her injuries. Initially represented by a Miami law firm and local counsel, a Los Angeles firm later took over. The District Court disqualified the Los Angeles firm due to misconduct involving attempts to influence a key witness, prompting the firm to appeal the disqualification.

Respondent Anne Koller was born without normal arms or legs. She filed suit in Federal District Court, alleging that during pregnancy her mother had taken an antinausea drug manufactured by petitioner and that this drug had caused respondent's birth defects.

Issue

Whether an order disqualifying counsel in a civil case is a collateral order subject to immediate appeal under 28 U.S.C. § 1291.

The Supreme Court, Justice O'Connor, held that order disqualifying counsel in civil case was not a collateral order subject to immediate appeal.

Rule

Orders disqualifying counsel in civil cases do not qualify as collateral orders for immediate appeal, as they do not conclusively determine a disputed question, resolve an important issue separate from the merits, and are effectively reviewable on appeal from a final judgment.

Held: Orders disqualifying counsel in a civil case are not collateral orders subject to immediate appeal as 'final judgments' within the meaning of § 1291.

Analysis

The Supreme Court analyzed the requirements for a collateral order and determined that disqualification orders do not meet these criteria. The Court emphasized that such orders are often intertwined with the merits of the case and that any potential prejudice from disqualification could be assessed after a final judgment, thus not warranting immediate appeal.

The Court of Appeals then held that the disqualification in question was invalid.

Conclusion

The Supreme Court concluded that the Court of Appeals lacked jurisdiction to entertain the appeal regarding the disqualification order, vacating the lower court's ruling and remanding the case.

Vacated and remanded with instructions.

Who won?

Richardson-Merrell, Inc. prevailed as the Supreme Court ruled that the disqualification order was not subject to immediate appeal, thereby upholding the District Court's authority.

The Court of Appeals subsequently held that it had jurisdiction to entertain the appeal pursuant to 28 U.S.C. § 1291.

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