Case No. 16-1150 | 3d Cir. Decision
There are those who insist on never conducting business with family members. Samuel Hall would have been wise to heed that advice. Samuel had been close to his mother Ethlyn Hall, an elderly landowner in the Virgin Islands, and had provided legal services to her free of charge. At one point, however, Samuel tried to develop one of the parcels of land Ethlyn owned in St. John, and their relationship deteriorated. Ethlyn claimed Samuel took advantage of her and cut off contact with him. Ethlyn’s health began to deteriorate so she moved to Florida to live with her daughter Elsa. Ethlyn altered her trust to designate Elsa as the sole successor trustee and filed suit against Samuel as both her attorney and as trustee of her inter vivos trust.
While motions in that case were pending, Ethyln died and Elsa took over as the personal representative of the Estate and the sole trustee of the trust. Samuel proceeded to file suit against Elsa in her individual capacity arguing that Elsa turned their mother against Samuel, took Ethlyn from the Virgin Islands without informing the family, and kept her hidden until her death. Samuel’s claims against Elsa were consolidated with the Estate’s claims against him.
At trial, the only claims remaining after various dismissals were the Estate’s fraud, unjust enrichment, and breach of fiduciary duty claims, and Samuel’s intentional infliction of emotional distress claim. The jury rejected all of the Estate’s claims and found Elsa liable for intentional infliction of emotional distress in the amount of $500,000 compensatory and $1,500,000 punitive damages.
Upon the verdict, the Estate immediately filed an appeal on its claims against Samuel. Elsa also filed a motion for a directed verdict or a new trial. It was concluded that the jury may have relied on a legally untenable basis for finding intentional infliction of emotional distress and a new trial was ordered.
Although Samuel’s claims warranted a new trial, the Estate’s appeal moved forward. Samuel filed a motion to dismiss arguing that the Third Circuit lacked jurisdiction because his claims against Elsa were still pending in District Court. The Estate’s argued that, although the cases were consolidated below, the district court entered two separate final judgements and the cases should not be consolidated for appeal. The Third Circuit determined that the factors of the case, such as the overlap of the claims, the relationship of the parties, and the fact that they had already been heard together deemed it appropriate that they be consolidated on appeal. Thus, the Third Circuit dismissed the Estate’s appeal for lack of jurisdiction until Samuel’s claims had been retried below.
The Estate appealed this decision to the Supreme Court, relying on the recent decision in Gelboim v. Bank of America, 135 S.Ct. 897 (2015), in which the Court held that a final judgement in a case was appealable even though that case was part of a multidistrict litigation in which other claims still remained. The Third Circuit distinguished that case by stating it is inapplicable because consolidation in multidistrict litigation is only used for pretrial matters. The Estate, however, wishes to know whether the Gelboim ruling should be extended to single district consolidated cases, so that the entry of a final judgment in one case triggers the appealability of that case.