Quackenbush v. Allstate Insurance Co.

Citation. 517 U.S. 706 (1996)

Brief Fact Summary.

Petitioner sued Respondent for breach of contract. Respondent removed the case and moved to compel arbitration. Petitioner argued the case should not be removed.

Synopsis of Rule of Law.

Under 28 U.S.C. § 1291, a district court’s order to remand is considered final for purposes of appeal.

Facts.

Insurance Commissioner for the State of California (Petitioner), the court appointed trustee of the insolvent Mission Insurance Company, sued Allstate Insurance Company (Respondent) for breach of contract. Respondent removed to federal court and filed a motion to compel arbitration. Petitioner moved to remand the case back to state court, because the contract dispute involving Mission Insurance Company was currently pending before state court.

Issue.

Is the District Court’s order to remand appealable under 28 U.S.C. § 1291?

Held.

Yes, the District Court’s order to remand the case was appealable under 28 U.S.C. § 1291. The decision of the Court of Appeals is affirmed.

Discussion.

The Court determined that the District Court’s decision to abstain from reviewing the case was appealable under 28 U.S.C. § 1291 because the decision was final. By remanding the case, the District Court effectively put the case out of court and surrendered jurisdiction to state court. Next, the Court determined that the District Court erred in abstaining from reviewing the case because the case involved important federal interests and would not disturb any important state interests or systems.