Woodward v. Credit Service International Corporation

Background

The court considered Lisa Woodward and Peter Woodward’s “Request for Entry of Judgment.” The request concerned an earlier order that granted in part the plaintiffs’ motion for attorney’s fees. The plaintiffs had filed a notice of appeal from that fee order and from a later order denying their request for reconsideration.

Court’s reasoning

Federal Rule of Civil Procedure 58(a) generally requires a judgment or amended judgment to appear in a separate document. But the rule expressly provides that a separate document is not required for an order disposing of a motion for attorney’s fees under Rule 54. The court also explained that, when a separate document is not required, the order is entered for purposes of the appeal deadline when it is entered on the civil docket under Federal Rule of Appellate Procedure 4(a). The court noted that an attorney-fee order is collateral to and independent from the merits of the litigation and can be separately appealed.

Disposition

The court denied the plaintiffs’ request for entry of a separate judgment concerning the attorney-fee order. Judge Katherine Menendez did not enter a separate judgment because the applicable rules did not require one.