Budinich v. Becton Dickinson & Co.
486 U.S. 196 (1988)
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Rule of Law:
A decision on the merits of a case is a 'final decision' for the purposes of appeal under 28 U.S.C. § 1291, even if a motion for attorney's fees attributable to the case remains to be adjudicated.
Facts:
- Petitioner Budinich was employed by Respondent Becton Dickinson & Co.
- A dispute arose concerning employment compensation that Budinich alleged was due to him.
- Budinich initiated an action to recover the disputed compensation.
- The relevant Colorado statute stipulated that in such employment compensation suits, the judgment for the winning party must include a reasonable attorney's fee.
Procedural Posture:
- Petitioner Budinich sued Respondent Becton Dickinson & Co. in Colorado state court.
- Respondent removed the case to the U.S. District Court for the District of Colorado based on diversity of citizenship.
- A jury rendered a verdict in favor of Petitioner, and the court entered judgment on March 26, 1984.
- Petitioner timely filed motions for a new trial and for attorney's fees.
- On May 14, 1984, the District Court denied the new-trial motions but ruled Petitioner was entitled to attorney's fees, deferring the determination of the amount.
- On August 1, 1984, the District Court issued its final order setting the amount of attorney's fees.
- On August 29, 1984, Petitioner filed a notice of appeal to the U.S. Court of Appeals for the Tenth Circuit.
- Respondent moved to dismiss the appeal of the merits judgment as untimely, arguing the 30-day appeal period started on May 14.
- The Court of Appeals dismissed the appeal concerning the merits as untimely but affirmed the attorney's fee award.
- The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts.
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Issue:
Does an unresolved issue of attorney's fees prevent a judgment on the merits from being a 'final decision' appealable under 28 U.S.C. § 1291?
Opinions:
Majority - Justice Scalia
No. An unresolved issue of attorney's fees does not prevent a judgment on the merits from being a final, appealable decision. The question of what constitutes a 'final decision' under 28 U.S.C. § 1291 is governed by federal law, not state law, even in diversity cases. A 'final decision' is one which ends the litigation on the merits and leaves nothing for the court to do but execute the judgment. A request for attorney's fees is a collateral issue, separate from the merits of the underlying action, as it does not remedy the injury that gave rise to the action. For the sake of operational consistency and predictability, a uniform, bright-line rule is necessary: a judgment on the merits is final regardless of whether a request for attorney's fees remains pending.
Analysis:
This decision establishes a critical bright-line rule for federal civil procedure, prioritizing jurisdictional certainty and judicial efficiency. By creating a uniform standard, the Court eliminated the confusion that arose from circuit splits and varying state laws that characterized attorney's fees differently. This ruling forces litigants to be vigilant about appeal deadlines for merits judgments, clarifying that they cannot wait for collateral matters like attorney's fees to be resolved. The case reinforces the principle that procedural rules governing federal court jurisdiction, like appealability, are determined by federal law, even when the underlying substantive claims are based on state law.
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