Brief Fact Summary. Carson is a class of former and present black employees and applicants of the Defendant which are alleging discrimination.
Synopsis of Rule of Law. An exception to the final judgment rule is that an interlocutory appeal that has serious and irreparable consequences will be appealable.
Although the district court's order did not in terms refuse an injunction, it nonetheless had the practical effect of doing so.View Full Point of Law
Issue. Whether an interlocutory order of the District Court denying a joint motion of the parties to enter a consent decree containing injunctive relief is an appealable order.
Held. Yes. When two parties wish to compromise and find an agreement, the court should allow this. The possible repercussion of not allowing such settlement between parties is so perverse that immediate appeal is the only appropriate remedy. Under the final judgment rule, parties may not appeal a decision of the court until a final judgment has been made. The Court has only allowed very narrow exceptions to that rule. One is interlocutory orders of district courts that grant, continue, modify, refuse or dissolve injunctions. Injunction decisions can cause serious and irreparable harm to parties; this is why appeals are allowed. While the denying of the consent decree is not an interlocutory order, it is much alike one because it is denying the parties ability to enter into an injunction which will benefit the plaintiffs. The plaintiffs show the irreparable harm because they must continue to work for Richmond without any effectual change to help their cause until the court finishes its review of the case.
Discussion. Courts should favor consent decrees because they allow the parties bargaining powers and the ability to compromise, and it allows the parties to avoid the cost of continued litigation.