## Facts

- Female employees sued Liberty Mutual Insurance Company under Title VII, alleging sex discrimination in employee insurance benefits and maternity-leave rules.
- The complaint sought multiple forms of relief, including injunctive relief, damages/back pay, costs, and attorneys’ fees.
- The district court granted partial summary judgment on liability only and did not resolve any requested remedies.
- The district court attempted to enter “final judgment” under Fed. R. Civ. P. 54(b), stating there was no just reason for delay, while withholding injunctive relief pending appeal and a requested stay.
- The Third Circuit treated the order as appealable under 28 U.S.C. § 1291 and affirmed on the merits.
- The Supreme Court granted certiorari to determine whether the order was appealable.

## Issues

1. Whether an order granting partial summary judgment on liability alone, leaving all requested remedies unresolved, is a “final decision” appealable under 28 U.S.C. § 1291.
2. Whether Fed. R. Civ. P. 54(b) can render such an order appealable in a single-claim action seeking multiple remedies.
3. Whether the order was appealable under 28 U.S.C. § 1292(a)(1) or § 1292(b).

## Decision

- The Supreme Court unanimously held the district court’s liability-only order was not appealable.
- The Court vacated the Third Circuit’s judgment and remanded with instructions to dismiss the appeal for lack of jurisdiction.
- The order was not final under § 1291 because it resolved only liability and left remedies to be determined.
- Rule 54(b) did not apply because the case involved a single claim, not multiple claims.
- The order was not appealable under § 1292(a)(1) because the appellant could not rely on a supposed refusal of an injunction directed at the opposing party’s requested relief.
- The order was not properly before the court under § 1292(b), including because the statutory permission-to-appeal procedure was not satisfied.

## Legal Principles

- An order deciding liability but leaving damages or other relief unresolved is interlocutory and not a “final decision” under 28 U.S.C. § 1291.
- Fed. R. Civ. P. 54(b) permits entry of final judgment only in multiple-claim actions after one or more claims have been fully resolved; seeking different remedies on a single legal theory does not create multiple claims.
- Appellate jurisdiction cannot be created by labeling an interlocutory liability ruling as “final” when the statutory requirements for appellate review are not met.
- A party generally may not invoke § 1292(a)(1) based on the absence or withholding of an injunction sought by the opposing party.
- Interlocutory review under § 1292(b) requires compliance with the statute’s certification and permission-to-appeal procedures.

## Conclusion

Because the district court resolved only Title VII liability while leaving all requested relief open, the order was interlocutory; Rule 54(b) could not convert it into a final judgment in a single-claim action, and no § 1292 basis supported the appeal, requiring dismissal for lack of appellate jurisdiction.


Liberty Mut. Ins. Co. v. Wetzel, 424 U.S. 737 (1976)