Richardson-Merrell Inc. v. Koller

Richardson-Merrell Inc. v. Koller
Supreme Court of the United States
Decided June 17, 1985
Full case name	Richardson-Merrell Inc. v. Koller
Citations	472 U.S. 424 ( more )
Holding
To fall within the collateral order exception to the final judgment rule, an order must conclusively determine the disputed question, resolve an important issue completely separate from the merits of the action, and be effectively unreviewable on appeal from a final judgment.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr.  · Byron White Thurgood Marshall  · Harry Blackmun Lewis F. Powell Jr.  · William Rehnquist John P. Stevens  · Sandra Day O'Connor
Case opinions
Majority	O'Connor
Concurrence	Brennan
Dissent	Stevens
Powell took no part in the consideration or decision of the case.

Richardson-Merrell Inc. v. Koller, 472 U.S. 424(1985), was a United States Supreme Court case in which the court held that to fall within the collateral order exception to the final judgment rule, an order must conclusively determine the disputed question, resolve an important issue completely separate from the merits of the action, and be effectively unreviewable on appeal from a final judgment. ^[1] This case stands for the final judgment rule itself: a party must ordinarily raise all of their appellate issues under one and only one appeal following a final judgment. ^[2]

Background

Anne Koller was born without arms or legs. She filed suit in federal District Court, alleging that, during pregnancy, her mother had taken an antinausea drug manufactured by Richardson-Merrell, and that this drug had caused her birth defects. Richardson-Merrell was initially represented by Miami and Washington law firms, but a Los Angeles law firm later took the lead in trial preparation. Before trial, the District Court disqualified the Los Angeles firm and revoked the appearances of two of its attorneys because of misconduct. Respondent appealed the disqualification to the D.C. Circuit Court of Appeals, which stayed all proceedings in the District Court pending the outcome of the appeal. The Court of Appeals thereafter held that 28 U.S.C. § 1291—which grants courts of appeals appellate jurisdiction for all "final decisions of the district courts," except where a direct appeal lies to the Supreme Court—confers jurisdiction over interlocutory appeals of orders disqualifying counsel in a civil case. The Court of Appeals then held that the disqualification in question was invalid. ^[1]

Opinion of the court

The Supreme Court issued an opinion on June 17, 1985. ^[1]

References

1. Richardson-Merrell Inc. v. Koller, 472 U.S. 424 (1985).
2. Brooke D. Coleman et al., Learning Civil Procedure 735 (3rd Ed. 2018).

External links

• Text of Richardson-Merrell Inc. v. Koller, 472 U.S. 424(1985) is available from: Cornell Findlaw Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain .