Rekor Systems, Inc. v. Loughlin
- Lewis Liman
- 1:19-cv-07767
- U.S. District Court · Southern District of New York
- 2
In Rekor Systems v. Loughlin, Judge Liman denied CrisisRisk’s request for immediate partial judgment because it showed no reason for delay.
CrisisRisk Strategies, LLC and Rekor Systems, Inc.; the court did not enter the requested $25,500.60 partial judgment.
What happened
In Rekor Systems, Inc. v. Loughlin, CrisisRisk Strategies, LLC asked the court to enter partial judgment requiring Rekor Systems, Inc. to pay $25,500.60. The request followed the court’s earlier grant of summary judgment for CrisisRisk on its counterclaim.
Rekor opposed the request, arguing that CrisisRisk had not shown there was no good reason to delay entering a final judgment while other matters remained. The court explained that this kind of partial judgment requires multiple claims or parties, a final decision on at least one claim or party, and a finding that delaying judgment would be unjustified.
The court denied CrisisRisk’s motion because CrisisRisk did not identify any benefit to efficient court administration or any hardship or injustice that would result from delaying partial judgment. Judge Lewis J. Liman directed the clerk to close the motion.
The detailed version
- Rekor Systems, Inc. v. Loughlin · No. 1:19-cv-07767
- Lewis Liman
- Apr. 20, 2022
Background
CrisisRisk Strategies, LLC, which was a counterclaim plaintiff, moved for partial judgment against Rekor Systems, Inc. in the amount of $25,500.60. The motion followed the Court’s earlier grant of summary judgment to CrisisRisk on its counterclaim.
Rule 54(b) Standard
Federal Rule of Civil Procedure 54(b) permits a court to enter a final judgment on fewer than all claims or parties only when three requirements are met: the case involves multiple claims or parties; at least one claim or party’s rights and liabilities have been finally decided; and the court expressly determines that there is no just reason to delay judgment. The court also explained that certification should generally serve sound judicial administration and efficiency, or address a risk of hardship or injustice caused by delay.
Rekor did not dispute that the first two requirements were satisfied. The only dispute concerned whether there was no just reason for delay.
Ruling
The Court found that CrisisRisk had not identified any reason why entering partial judgment would promote sound judicial administration or efficiency. CrisisRisk also had not shown any hardship or injustice that would result from delaying entry of partial judgment. The Court therefore denied CrisisRisk’s motion. The clerk was directed to close Docket Number 217.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.