Sarah E. Martin v. PEI Ohio, Inc., and Premium Transportation Group, Inc. (Appeal from Jefferson Circuit Court…

Summary

The Alabama Supreme Court dismissed both of Sarah E. Martin's appeals, holding that the trial court exceeded its discretion by improperly certifying the settlement‑enforcement order and the attorney‑fee award as final judgments under Rule 54(b). The Court reasoned that the third requirement for a Rule 54(b) certification – a finding that there is no just reason for delay – was not satisfied, and that piecemeal appellate review would be inefficient.