Reguli v. Woodruff et al

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
CONNIE REGULI,
Plaintiff,
v.
JOESEPH A. WOODRUFF et al.,
Defendants.
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Case No. 3:24-cv-00694
Judge Aleta A. Trauger
MEMORANDUM and ORDER
The court previously granted defendant Judge Joseph Woodruff’s Motion to Dismiss on
the grounds of absolute judicial immunity (see Doc. Nos. 52, 53) and, in a separate Order (Doc.
No. 119), deferred ruling on Woodruff’s Motion for Entry of Final Judgment Pursuant to Federal
Rule of Civil Procedure 54(b) (Doc. No. 94), pending the Sixth Circuit’s determination of whether
to permit an interlocutory appeal of the court’s Orders (Doc. Nos. 53, 118) rejecting defendant
Emily Layton’s claim that she is entitled to absolute witness liability.
The Sixth Circuit has now denied Layton’s request for an interlocutory appeal and
dismissed the appeal (see Doc. No. 126), bringing back to the foreground Woodruff’s Motion for
Entry of Final Judgment. That motion, as set forth herein, will be denied.
Federal Rule of Civil Procedure 54(b) provides, “[w]hen an action presents more than one
claim for relief . . . or when multiple parties are involved, the court may direct entry of a final
judgment as to one or more, but fewer than all claims or parties only if the court expressly
determines there is no just reason for delay.” Under this rule, a district court may certify a partial
grant of summary judgment for immediate appeal if the court “‘expressly determines that there is
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no just reason for delay.’” Greene v. Crawford Cnty., 22 F.4th 593, 604–05 (6th Cir. 2022)
(quoting Carpenter v. Liberty Ins. Corp., 850 F. App’x 351, 353 (6th Cir. 2021)). Certification
under Rule 54(b) is a “two-step process.” Id. (quoting Planned Parenthood Sw. Ohio Region v.
DeWine, 696 F.3d 490, 500 (6th Cir. 2012)). First, the district court must “expressly direct the
entry of final judgment as to one or more but fewer than all the claims or parties in a case.” Id.
(citation and quotations omitted). Second, “the district court must expressly determine that there
is no just reason to delay appellate review.” Id. (citation omitted).
The Sixth Circuit has provided a “non-exhaustive list of factors” a district court should
consider in addressing this second step, including:
(1) the relationship between the adjudicated and unadjudicated claims; (2) the
possibility that the need for review might or might not be mooted by future
developments in the district court; (3) the possibility that the reviewing court might
be obliged to consider the same issue a second time; (4) the presence or absence of
a claim or counterclaim which could result in set-off against the judgment sought
to be made final; (5) miscellaneous factors such as delay, economic and solvency
considerations, shortening the time of trial, frivolity of competing claims, expense,
and the like. Depending upon the facts of the particular case, all or some of the
above factors may bear upon the propriety of the trial court’s discretion in certifying
a judgment as final under Rule 54(b).
Corrosioneering, Inc. v. Thyssen Env’t Sys., Inc., 807 F.2d 1279, 1283 (6th Cir. 1986) (citations
omitted). Essentially, the court must “balance the needs of the parties against the interests of
efficient case management.” Gen. Acquisition, Inc. v. GenCorp, Inc., 23 F.3d 1022, 1027 (6th Cir.
1994)). “Not all final judgments on individual claims should be immediately appealable, even if
they are in some sense separable from the remaining unresolved claims.” Id. (quoting Curtiss-
Wright Corp. v. Gen. Elec. Co., 446 U.S. 1, 8 (1980)). “Courts implementing Rule 54(b) must
strike a balance between the undesirability of more than one appeal in a single action and the need
for making review available in multiple-party or multiple-claim situations at a time that best serves
the needs of the litigants.” Id. (internal quotation marks and citation omitted). Interlocutory appeals
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should be limited to “infrequent harsh case[s],” so as to “alleviate hardship resulting from
unnecessary delay without undermining ‘the historic federal policy against piecemeal appeals.’”
Id. (first quoting Rudd Constr. Equip. Co., Inc. v. Home Ins. Co., 711 F.2d 54, 56 (6th Cir. 1983);
and then quoting Curtiss-Wright, 446 U.S. at 8).
For purposes of the first step, the court’s Order on the Motions to Dismiss in March 2025
disposed of one or more but fewer than all claims and parties in this case. The court dismissed, on
the grounds of absolute judicial immunity, all claims against Woodruff. The order constituted an
“ultimate disposition” of all claims against Woodruff “entered in the course of a multiple claims
action.” Curtis-Wright, 446 U.S. at 7 (citation omitted).
Some of the factors to be considered at the second step weigh in favor of entry of final
judgment. For instance, it does not appear that future developments in this court will moot the need
for review; there are no counterclaims or crossclaims that might result in a set-off against a
judgment; and, because Woodruff is the only defendant who claims judicial immunity, the Sixth
Circuit would only need to consider that particular issue once.
On the other hand, the claims against all defendants and the facts supporting those claims
are closely intertwined, as the plaintiff maintains that the defendants entered into a conspiracy to
engage in a malicious prosecution against her. If the appellate court disagrees with this court on
the issue of judicial immunity, the claims against all the defendants would need to be considered
in tandem. This factor weighs heavily against certification of final judgment against Woodruff.
In addition, the final factor does not weigh in favor of certification. Woodruff maintains
that it does because the appellate court will only need to consider the issue of judicial immunity
once, no other defendants claim judicial immunity, and “the policy of the law favors the resolution
of immunity defenses as early in a lawsuit as may be practicable.” (Doc. No. 94 at 8 (quoting
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Nystedt v. Nigro, 700 F.3d 25, 30 (1st Cir. 2012)).) However, the court finds that Woodruff has no
need to appeal, and severing the appellate process will almost certainly require the plaintiff to
pursue piecemeal appeals—one while the remainder of the case remains pending in this court and
one later, after entry of final judgment either for or against the plaintiff on her claims against the
other defendants. And the appellate court would also have to consider two separate appeals
involving the same set of facts. Finally, Woodruff does not claim that he will suffer any particular
prejudice or injury as a result of being required to wait until resolution of the case as a whole before
the plaintiff may pursue an appeal of the dismissal of the claims against him. This factor, therefore,
weighs heavily against certifying entry of final judgment.
Weighing all of these factors together, the court finds that there is just reason for delay and
that certification of final judgment is not warranted. Accordingly, Woodruff’s Motion for Entry of
Final Judgment Pursuant to Federal Rule of Civil Procedure 54(b) (Doc. No. 94) is hereby
DENIED.
It is so ORDERED.
ALETA A. TRAUGER
United States District Judge
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