Curtiss-Wright Corp. v. General Electric Co.

Brief Fact Summary.

Petitioner sued Respondent for breach of contract. Respondent counterclaimed for money owed based on performance of the contract. Petitioner moved for summary judgment.

Synopsis of Rule of Law.

Under Rule 54(b), the district court must determine that the judgment is final  and there is no just reason for delay. A reviewing court should give deference to the district court’s determination, absent clear abuse of discretion.

Facts.

Curtiss-Wright (Petitioner) sued General Electric Co. (Respondent) for  $19 million, claiming breach of contract, fraud, and misrepresentation. Respondent filed a counterclaim  for the costs of Respondent’s efforts in performance of the contract and unjust enrichment incurred by Petitioner. Petitioner moved for summary judgment on the claim for $19 million. Respondent argued granting summary judgment would bar recovery on the other pending issues of the case.

Issue.

Did the District Court properly grant a final judgment for Petitioner under Rule 54(b)?

Held.

Yes, the District Court properly granted a final judgment for Petitioner under Rule 54(b). The decision of the Third Circuit Court of Appeals is reversed.

Discussion.

The Court determined that the District Court properly considered both the finality of the judgment and any just reasons for delay before certifying the judgment under Rule 54(b). The District Court determined that the claim was separable from the remaining claims and counterclaims, and weighed the inequity regarding the market rates affecting both parties debts. The Court of Appeals erred by not giving substantial deference to these decisions.