Famuyide v. Chipotle Mexican Grill, Inc.

Background

Chipotle Mexican Grill, Inc., and Chipotle Services, LLC, collectively called Chipotle in the opinion, asked for permission under the court’s local rules to file a motion for reconsideration of the court’s August 31, 2023 order. That earlier order denied Chipotle’s motion to compel arbitration. Eniola Famuyide opposed Chipotle’s request.

While the request for permission was pending, Chipotle filed a notice of interlocutory appeal to the U.S. Court of Appeals for the Eighth Circuit. An interlocutory appeal is an appeal taken before the case is completely finished.

Court’s analysis

The court explained that a district court generally loses authority over matters involved in an appeal once the appeal has been filed. Because Chipotle had filed its notice of appeal, the court concluded that it no longer had jurisdiction—the legal authority to decide—the request to reconsider the earlier order.

The court considered Federal Rule of Civil Procedure 62.1, which can allow a district court to issue an indicative ruling when a timely motion seeks relief the court cannot grant because of a pending appeal. The court held that the rule did not apply because Chipotle had not filed a reconsideration motion. It had asked only for permission to file one, as required by the local rule. The court added that even if Rule 62.1 applied, it would defer consideration of the request at that time.

Disposition

The court ordered that Chipotle’s request to file a motion to reconsider the August 31, 2023 order was DENIED WITHOUT PREJUDICE. The opinion did not decide the merits of Chipotle’s proposed reconsideration motion or the underlying dispute over arbitration.