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The post below was published on Tuesday, January 25th, 2011 at 9:58 AM.

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U.S. Supreme Court: An Important Summary Judgment Lesson

This decision, released yesterday by the U.S. Supreme Court, could affect federal and state practice at both the trial and appellate levels.

Longtime Abstract Appeal readers may have noticed that I occasionally make somewhat awkward mention of the fact an appellate court reversed a summary judgment denial after the case proceeded to trial. Coincidentally, I did so just last Tuesday, in this post involving a recent Second District decision. I never delve further, with Florida law not being clear on the point, but those paying close attention may observe my skepticism regarding whether a summary judgment decision can be reviewed after a case proceeds to trial.

The Supreme Court’s decision from yesterday holds that it cannot. Whether the court’s broad language is as comprehensive as it appears is not certain.

The case involved a section 1983 claim against prison officials who sought summary judgment based on qualified immunity. The district court denied the motion and the case proceeded to trial. There, the defendants lost, and without filing a post-trial Rule 50(b) motion, they appealed. The Sixth Circuit reversed, holding that while summary judgment decisions are not ordinarily reviewable after a trial on the merits, qualified immunity presents an exception. The plaintiff then petitioned for review by the Supreme Court, which reversed the circuit court decision.

The Supreme Court spoke in broad terms:

We granted review to decide a threshold question on which the Circuits are split: May a party, as the Sixth Circuit believed, appeal an order denying summary judgment after a full trial on the merits? Our answer is no. The order retains its interlocutory character as simply a step along the route to final judgment. Once the case proceeds to trial, the full record developed in court supersedes the record existing at the time of the summary judgment motion. A qualified immunity defense, of course, does not vanish when a district court declines to rule on the plea summarily. The plea remains available to the defending officials at trial; but at that stage, the defense must be evaluated in light of the character and quality of the evidence received in court.

(footnote and citations omitted).

The prison officials argued that a distinction exists between summary judgment motions that turn on the sufficiency of the evidence and those that present purely legal issues capable of resolution with reference to undisputed facts. The Court characterized the latter as usually involving “disputes about the substance and clarity of pre-existing law” and decided that it need not address the argument because the case involved not a dispute over pre-existing law but the facts that could render the prison officials liable.

The court went further and held that, to the extent the prison officials disputed that the plaintiff proved her case, they were required to raise that issue through a Rule 50(b) motion. Because they did not do so, the circuit court could not consider that matter.

How broadly this decision will be applied, and whether such a pronouncement by the nation’s highest court will affect state court practice, remains to be seen.

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