Will v. Hallock (2005)
- Docket
- 04-1332
- Decided
- 2005-01-01
Summary
Question: 1) If a claim under the FTCA is dismissed on the grounds that it is covered by one of the Act's exceptions to the waiver of sovereign immunity, is the dismissal a final judgment that bars a subsequent suit against the individual federal employees who were involved? 2) Did the Circuit Court have jurisdiction under the collateral order doctrine to hear an appeal of the District Court's order? Conclusion: Unanswered, and no. In a unanimous opinion, the Court ruled that the Circuit Court had no jurisdiction to hear an appeal under the collateral order doctrine. Writing for the Court, Justice David Souter stressed the narrow scope of the doctrine. The Court reiterated that only orders that cannot be "effectively" reviewed after a final judgment can be appealed before the close of the trial. Essential to this determination is the importance of the interest at stake. In this case, the Court ruled that the agents' interest in appealing the District Court's order had no "greater importance than the typical defense of claim preclusion" and it therefore warranted "no immediate appeal of right as a collateral order."