Litigation in Federal Court

Judgment

Trial

Judgment

Relief from Judgment

FRCP 59: New Trial

• A new trial may be granted if:

[1] The instructions were confusing to the jury or provided a disproportionate remedy.

[2] Jury deliberations were tainted.

[3] New evidence emerges within 28 days of dismissal.

FRCP 60: Relief from Judgment

• Relief from judgment may be allowed if:

[1] New evidence emerges within 28 days of jury dismissal.

[2] Fraud occurred

Appeals

28 U.S.C. §1291: The Finality Rule

• Courts of Appeal have automatic Subject Matter Jurisdiction over final orders from District Courts.      

FRCP 58: Final Order Requirement

• Without a final order, appellate courts approach appeals with a high level of skepticism.

Exceptions

[1] Collateral Rule Doctrine:

• Issues may be reviewed before a final order if they’re:

Separate: issue is separate from merits of the original claim.

Final: issue can be fully resolved on appeal.

Urgent: issue involves irreparable harm.

Important: discretionary judgment of the court.

[2] 28 U.S.C. §1651(a): Mandamus

• Writ-based review of non-final orders. A plaintiff must show:

[1] Special risk of irreparable harm; “no other adequate means of relief”

[2] Clear entitlement to relief (most common: jurisdiction challenges)

[3] FRCP 54(b): Multiple Claims or Parties

• Allows an appeal from a final order entered on an issue in a case, even if the case as a whole is still ongoing.

• “Spot Golden Ticket”

[4] 28 U.S.C. §1292: Specifically Authorized Interlocutory Appeals

• Allows injunctions, receivers, admiralty, and other accepted issues to be appealed before a case is closed.