N.A.A.C.P. v. American Family Mutual Insurance Co.

Brief Fact Summary.

The NAACP sued American Family Mutual Insurance Co. (AFMI) alleging that the AFMI’s use of redlining violated the Fair Housing Act (Title VIII), federal laws prohibiting racial discrimination in contracts and real property, Wisconsin’s fair housing act, and state insurance laws.

Synopsis of Rule of Law.

A district judge is permitted to enter final judgment on fewer than all claims in a suit if the judgment resolves the claim in its entirety or resolves all claims concerning an individual party.

Facts.

The NAACP sued American Family Mutual Insurance Co. (AFMI) alleging that the AFMI’s use of redlining violated the Fair Housing Act (Title VIII), federal laws prohibiting racial discrimination in contracts and real property, Wisconsin’s fair housing act, and state insurance laws. The district judge dismissed the Title VIII and state insurance claims and the plaintiffs appealed.

Issue.

Whether a district judge is required to enter final judgment on all claims in a suit?

Held.

Yes. Dismissal of the state-law claim is affirmed and dismissal of the Title VIII claim is reversed. Plaintiffs are prohibited from bringing successive lawsuits for the same claims arising under different laws. Judgment should not be entered if for claims involving similar facts and theories.

Discussion.

FRCP 54(b) permits a district judge to enter final judgment on fewer than all claims in a suit if the judgment resolves the claim in its entirety or resolves all claims concerning an individual party.