Swint et al. v. Chambers County Commission et al.
514 U.S. 35 (1995)
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Rule of Law:
A federal court of appeals does not have 'pendent appellate jurisdiction' to review a district court's non-appealable order denying a county's motion for summary judgment, even when it has jurisdiction over a separate, immediately appealable 'collateral order' denying qualified immunity to individual co-defendants in the same case.
Facts:
- On December 14, 1990, and March 29, 1991, law enforcement officers from Chambers County and the city of Wadley, Alabama, conducted two raids on the Capri Club.
- The raids were part of a narcotics operation.
- Chambers County Sheriff James C. Morgan authorized the raids.
- The raids were conducted without a search warrant or an arrest warrant.
- L. R. Swint, one of the club's owners, along with another owner, an employee, and a patron, were subjected to the raids.
Procedural Posture:
- L. R. Swint and other plaintiffs sued the Chambers County Commission, the city of Wadley, and three individual police officers in the U.S. District Court for the Middle District of Alabama for civil rights violations.
- All defendants moved for summary judgment; the individual officers asserted qualified immunity and the County Commission argued the sheriff was not its policymaker.
- The District Court denied all motions for summary judgment.
- The individual officers, as appellants, immediately appealed the denial of qualified immunity to the U.S. Court of Appeals for the Eleventh Circuit.
- The Chambers County Commission, also as an appellant, appealed the denial of its summary judgment motion, arguing for either collateral order jurisdiction or pendent appellate jurisdiction.
- The Eleventh Circuit held it had jurisdiction over the individual officers' appeal and, exercising pendent appellate jurisdiction, also took up the County Commission's appeal.
- The Eleventh Circuit reversed the District Court's denial of summary judgment for the County Commission, holding that the sheriff was not a county policymaker.
- Swint et al. successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a federal court of appeals, after acquiring jurisdiction to review a district court's interlocutory order denying summary judgment to individual defendants on qualified immunity grounds, also have 'pendent appellate jurisdiction' to review a simultaneous order denying summary judgment to a county defendant on the separate issue of municipal liability?
Opinions:
Majority - Justice Ginsburg
No. A court of appeals lacks pendent appellate jurisdiction to review an otherwise non-appealable order simply because it is presented in conjunction with an appealable collateral order. The court first determined that the denial of the County Commission's summary judgment motion was not an appealable 'collateral order' under the Cohen doctrine. The district court's ruling was tentative, not conclusive, and the Commission's claim that the sheriff was not its policymaker is a defense to liability, not an immunity from suit, which can be effectively reviewed after a final judgment. The Court then rejected the Eleventh Circuit's exercise of 'pendent appellate jurisdiction,' reasoning that such a judge-made doctrine undermines the specific statutory scheme Congress created in 28 U.S.C. §§ 1291 and 1292 to govern the timing of appeals. Congress has provided specific mechanisms for interlocutory appeals, such as § 1292(b) certification, and has granted the Supreme Court rulemaking authority to define finality, indicating that jurisdiction should not be expanded by judicial invention for reasons of economy. The Court held that unlike the limited instances where pendent jurisdiction may be appropriate, the County Commission's liability issue was not 'inextricably intertwined' with, nor was its review 'necessary to ensure meaningful review of,' the individual officers' qualified immunity claims.
Analysis:
This decision significantly restricts the doctrine of pendent appellate jurisdiction, reinforcing a strict interpretation of the final judgment rule and congressional control over federal court jurisdiction. By rejecting judicial economy as a sufficient basis for hearing an otherwise non-appealable interlocutory order, the Court prevents parties from using an appealable collateral order as a 'ticket' to bring other, unrelated issues before an appellate court prematurely. The ruling clarifies that for pendent appellate jurisdiction to be proper, the appealable and non-appealable orders must be 'inextricably intertwined,' a much higher standard than mere relatedness or convenience. This reinforces the policy against piecemeal litigation and directs parties to use statutorily prescribed routes, like § 1292(b) certification, for seeking early appellate review.
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