Tawfik v. Select Portfolio Servicing, Inc.

Background

JPMorgan Chase Bank, N.A. filed an unopposed motion asking the court to enter final judgment under Federal Rule of Civil Procedure 54(b). The court had previously granted Chase’s motion to dismiss with prejudice, and the opinion states that all claims against Chase had been dismissed. The case involved multiple parties and claims.

Rule 54(b) analysis

Rule 54(b) allows a court to enter final judgment on fewer than all claims or parties in a case involving multiple claims or parties. The court must determine that the resolved claims have been finally disposed of and that there is no just reason to delay judgment.

The court found that dismissal of all claims against Chase was an ultimate disposition of those claims. It also found that the claims against Chase were separable from the claims involving the other defendants because they were based on a separate loan instrument and property. The court stated that entry of judgment would serve administrative interests and would not undermine the policy against piecemeal appeals. The equities also favored entry of judgment because the plaintiffs did not oppose the motion and had not identified any prejudice.

Ruling

Judge Corley vacated the October 8, 2020 hearing and granted Chase’s motion for entry of final judgment. This order concerns entry of judgment under Rule 54(b); it does not explain the basis for the earlier dismissal with prejudice.