Curtiss-Wright Corp. v. General Electric Co.

Background

A manufacturer (Curtiss‑Wright) and a contractor (General Electric) had 21 contracts worth $215 million for naval components. Curtiss‑Wright sued in New Jersey in 1976 seeking damages and $19 million unpaid on performed contracts. General Electric counterclaimed for $1.9 million in costs and $52 million in alleged unjust enrichment. The District Court applied New York law, granted summary judgment to Curtiss‑Wright for the $19 million, awarded 6% prejudgment interest, and then certified that judgment as final under Rule 54(b).

Reasoning

The Court considered whether a district judge may certify a final judgment for immediate appeal when other claims or counterclaims remain. Relying on earlier decisions, the Court said the district court must first find the decision is final on an individual claim and then determine there is no just reason to delay appeal. The mere presence of counterclaims does not automatically bar certification. Appellate courts should not reweigh the district court’s balancing of judicial administration and fairness; they should reverse only if the district court’s conclusion was clearly unreasonable. The Court concluded the District Court did not abuse its discretion, reversed the Court of Appeals, and sent the case back for further proceedings.

Real world impact

District judges can certify separable money judgments for immediate appeal when they reasonably find no just reason for delay. That can let a winning party seek collection sooner while other claims are litigated. The Court noted tools like stays or deposits to protect parties while appeals proceed.