Euna McGruder v. Metro. Gov't of Nashville
- Summarized by J. Debbeler , Bricker Graydon LLP
- 1 year 10 months ago
- Case Type:
- Consumer
- Case Status:
- Affirmed
- Citation:
- No. 22-5761: File Name: 24a0089p.06 (6th Circuit, Apr 17,2024) Published
- Tag(s):
-
- Ruling:
- A party's judicial estoppel claim cannot create a previously unrecognized exception to the long-standing jurisdictional rule that generally appellate courts have authority to rule only on final orders from district courts. The district court did not abuse its discretion when it found that employing judicial estoppel to bar the employee's reinstatement claims would not serve the goals of that doctrine. Judicial estoppel should be applied with caution to avoid impinging on the truth-seeking function of the court.
- Procedural context:
- In 2017, an employee brought a Title VII claim in district court against her employer that her termination constituted illegal retaliation. After filing the Title VII suit, the employee filed a Chapter 7 bankruptcy in 2018 and did not disclose the existence of her suit in the bankruptcy schedules. The employee claimed she told her bankruptcy lawyer about the suit. She received her discharge and the case closed.
At trial in 2021, the employee received a jury verdict for $260,000 for compensatory damages and nothing for back pay. She filed a post trial motion for back pay and for attorneys fees. The district court granted the motion for attorney fees and set aside the failure to grant back pay., ordering a new trial on that issue. The district court ordered her reinstatement to her prior position.
The employer appealed the reinstatement order and moved to stay the order pending appeal. After filing the appeal, the employer found out about the bankruptcy. It moved the district court to dismiss the case with prejudice due to judicial estoppel. The employee notified the bankruptcy court of her claim and requested the case be reopened. The district court found it had no jurisdiction to consider the judicial estoppel claims due to the earlier appeal divesting it of jurisdiction. It stayed the reinstatement order.
- Facts:
- The Sixth Circuit found that the employer's notice of appeal did not allege any judicial estoppel arguments as it filed the appeal before it found out about the bankruptcy. The court found that the employee was well aware of the employer's judicial estoppel claim. While the court stated in could not ordinarily consider non-final orders, the reinstatement claim was an exception to the general rule as it was in the form of an injunction. The court found it could not find jurisdiction to consider claims not before it such as the back pay, attorneys fees and damages nor consider any possible judicial estoppel claims regarding those issues. Any consideration of judicial estoppel on those issues had to await a final district court order.
Reinstatement was another issue for the court. The court found that reinstatement would not run afoul of judicial estoppel as there would be no impact on the bankruptcy estate, unlike the claim for damages. Accordingly, the reinstatement order was not barred by judicial estoppel.
- Judge(s):
- Batchelder, Moore and Clay, Circuit judges
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