Lee v. Trump

Summary

The United States District Court for the District of Columbia addresses motions by Donald J. Trump and the United States to stay consolidated proceedings pending interlocutory appeals concerning official-acts immunity and Westfall Act substitution. The court stays all proceedings in Lee and several other consolidated cases, while permitting Smith to proceed except that discovery remains stayed as to President Trump. The court denies a complete stay in Smith and denies the United States’ motion to stay proceedings there.

Holdings

1. Consolidated cases retain their separate identities and substantial rights, so the consequences of an interlocutory appeal must be determined case by case rather than for the consolidated matters as a whole.
2. When President Trump is the sole defendant and has an immediate interlocutory appeal from an immunity ruling, all proceedings must be stayed pending appellate review.
3. The interlocutory immunity appeal requires that discovery remain stayed as to President Trump in Smith, but it does not require a stay of proceedings involving the other defendants and third parties.
4. The proceedings in Lee must be stayed in their entirety pending appellate review.
5. The United States may seek ancillary relief to preserve its claimed party status despite not presently being a party, but its motion for a stay in Smith is denied.

Questions Presented

1. Whether President Trump's interlocutory appeal concerning official-acts immunity required a stay of all proceedings in each consolidated case.
2. Whether the appeal required a complete stay of Smith, or only a stay of discovery as to President Trump.
3. Whether the narrower scope of Lee made its proceedings sufficiently intertwined with the immunity appeal to require a complete stay.
4. Whether the United States could seek a stay despite not being a current party after its Westfall Act substitution request was rejected.
5. Whether the discretionary four-factor test supported a complete stay of Smith.

Disposition

other