Liberty Mutual Insurance Company v. Wetzel

Supreme Court of the United States · 1976 · Civil Procedure

424 U.S. 737 (1976)

Updated July 29, 2026

Civil ProcedureAppellate JurisdictionFinal Judgment RuleRule 54(b)Interlocutory Appeals28 U.S.C. § 129128 U.S.C. § 1292partial summary judgment

Facts

Respondents alleged that Liberty Mutual's employee insurance benefits and maternity leave regulations discriminated against women in violation of Title VII. Their complaint sought several forms of relief, including injunctions, damages, attorneys' fees, and other appropriate relief. After discovery, respondents moved for partial summary judgment only on liability, and the District Court held that certain pregnancy-related policies violated Title VII. The District Court did not award the requested injunction, damages, or attorneys' fees, but later amended its order under Rule 54(b) and directed entry of judgment with a finding of no just reason for delay.

Issue

Was the District Court's order determining Liberty Mutual's liability under Title VII, while leaving unresolved respondents' requests for injunctive relief, damages, and attorneys' fees, appealable to the Court of Appeals? More specifically, could Rule 54(b), § 1291, or § 1292 authorize an appeal from that order?

Rule

Rule 54(b) applies only in multiple-claim or multiple-party actions and cannot make appealable an order in a single-claim action merely because the court has resolved liability while leaving relief unresolved. A complaint asserting one legal right states a single claim for relief even if it seeks multiple remedies. A partial summary judgment limited to liability is interlocutory and is not a final decision under 28 U.S.C. § 1291 when damages or other relief remain to be determined.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Chicago, Nina Flores sues Lakefront Transit Services under one federal statute, alleging the company maintained a single unlawful compensation policy against her and similarly situated employees. Her complaint seeks an injunction, back pay, punitive damages, and attorney's fees. The district court grants summary judgment for Nina on liability only, leaves all requested relief for later, and adds Rule 54(b) language stating there is no just reason for delay.

Is the employer's immediate appeal most likely proper under 28 U.S.C. § 1291?

Explanation. A complaint asserting one legal right based on one set of facts states a single claim for relief even if it requests several remedies. In a single-claim action, Rule 54(b) does not apply, so a liability-only summary judgment that leaves injunction, damages, or fees unresolved is interlocutory rather than final under § 1291. (Derived from Liberty Mutual Insurance Company v. Wetzel (1976).)