Serra Chevrolet, Inc. v. General Motors, LLC

Summary

The United States District Court for the Northern District of Alabama granted the parties’ joint motion to vacate its interlocutory summary judgment and reconsideration orders after the parties reached a comprehensive settlement. Applying Federal Rule of Civil Procedure 54(b) and equitable balancing principles concerning settlement-related vacatur, the court concluded that the nonfinal, nonbinding orders should be vacated. The parties were ordered to file a joint stipulation of dismissal with prejudice or a status report by June 10, 2026.

Holdings

1. A district court has equitable discretion under Federal Rule of Civil Procedure 54(b) to revise or vacate its own interlocutory orders before entry of final judgment; the appellate-vacatur exceptional-circumstances test from U.S. Bancorp Mortgage Co. v. Bonner Mall Partnership does not categorically restrict that discretion.
2. Vacatur of the interlocutory summary-judgment and reconsideration orders was warranted because the orders were nonfinal and nonbinding, the surviving claims were never tried or reviewed on appeal, the parties demonstrated concrete commercial and practical interests, and those interests and the interests of finality and judicial economy outweighed the public interest in preserving the orders.

Questions Presented

1. Whether a district court may vacate its own interlocutory summary-judgment and reconsideration orders under Federal Rule of Civil Procedure 54(b) after the parties settle.
2. Whether the equitable balance of private, settlement-related, judicial-resource, and public interests warranted vacatur of the interlocutory orders in this case.

Disposition

vacated