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

Citation. 978 F.2d 287 (7th Cir. 1992)

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Citation978 F.2d 287 (7th Cir. 1992)

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.

Points of Law - Legal Principles in this Case for Law Students.

We find, based on the historical context, the legislative history, and judicial interpretations of that history, that Congress, in enacting a statute primarily intended to deal with the conflict between state regulation of insurers and the federal antitrust laws, had no intention of declaring that subsequently enacted civil rights legislation would be inapplicable to any and all of the activities of an insurance company that can be classified as the business of insurance.

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Facts.

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.

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