Settlement Enforcement Orders Do Not Constitute Final Decisions Under 28 U.S.C. §1291 Unless They Dispose of All Claims

Introduction

The Eleventh Circuit’s decision in Tiana Hill v. Clayton County, Georgia (No. 23-12884, May 20, 2025) addresses the narrow but important question of appellate jurisdiction over a district court’s order enforcing a settlement agreement. The plaintiff, Tiana Hill, sued Clayton County, the Sheriff, and private medical‐care contractors for alleged Eighth and Fourteenth Amendment violations in the medical treatment—or lack thereof—she received while detained and pregnant in the Clayton County Jail. After settling with one set of defendants (the medical contractor and its physician), Hill amended her complaint and re-filed claims against the County and Sheriff Hill. The County and Sheriff moved to enforce the prior settlement, asking the district court to strip out all “medical and medical-related” claims. When the district court granted that motion but left open the case for further amendment, Hill appealed. The sole issue before the Eleventh Circuit was whether that order is a “final decision” under 28 U.S.C. § 1291, thereby permitting immediate appeal.

Summary of the Judgment

Per curiam, the Eleventh Circuit held that the district court’s order enforcing the settlement agreement is not a final, appealable decision. The court emphasized that under § 1291, a final decision must dispose of all claims and leave nothing for the district court to do but execute the judgment. Because the district court neither dismissed Hill’s remaining claims nor entered judgment, and in fact contemplated further amendments, the order was interlocutory. The Eleventh Circuit therefore granted the County and Sheriff’s motion to dismiss the appeal for lack of jurisdiction.

Analysis

Precedents Cited

28 U.S.C. § 1291: Limits appellate jurisdiction to “final decisions.”
Acheron Capital, Ltd. v. Mukamal, 22 F.4th 979, 986 (11th Cir. 2022): Reiterates that a final decision ends litigation on the merits.
Supreme Fuels Trading FZE v. Sargeant, 689 F.3d 1244, 1246 (11th Cir. 2012): An order disposing of fewer than all claims is not final.
Freyre v. Chronister, 910 F.3d 1371, 1377 (11th Cir. 2018): An order that contemplates further substantive proceedings is interlocutory.
Massachusetts Casualty Insurance Co. v. Forman, 469 F.2d 259, 260 (5th Cir. 1972): A settlement enforcement order can be final when it disposes of the primary dispute.
Goldstein v. Andresen & Co., 465 F.2d 972, 973 (5th Cir. 1972): Absent dismissal or judgment on the merits of all claims, a settlement enforcement order is not appealable.
Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc): Adopts pre-1981 Fifth Circuit precedents as binding.

Legal Reasoning

The court’s ruling rests on the classic “final decision” doctrine. Section 1291 provides that only final decisions of the district courts are appealable. A final decision must:

End the litigation on the merits;
Leave nothing for the district court to do but execute the judgment.

Here, although the district court enforced a settlement agreement by ordering Hill to remove her medical‐related claims, it did not dismiss any claim or enter final judgment. Instead it invited further briefing and amendment. The Eleventh Circuit found that under Freyre and Supreme Fuels Trading, an order contemplating additional substantive steps in the litigation cannot be final. And although Fifth Circuit decisions such as Forman recognize that settlement enforcement orders can sometimes be final, those cases turned on the order’s disposing of the core dispute in its entirety. In contrast, the district court’s order left Hill’s case alive below.

Impact

This decision reinforces the strict finality requirement for appellate jurisdiction and clarifies the limited circumstances under which settlement enforcement orders are appealable. Practitioners should note:

When enforcing a settlement, obtain a district‐court order that definitively dismisses or enters judgment on all claims you intend to remove if you wish to preserve an immediate right to appeal;
Counsel for plaintiffs should be wary of prematurely filing notices of appeal from orders that leave significant claims pending;
District courts should be explicit in their orders about dismissals or judgments to avoid interlocutory‐appeal traps;
The decision delineates the interplay between Federal Rule of Civil Procedure 21 (misjoinder) and Rule 41(a)(2) (dismissal by court order) in the context of settlement enforcement.

Complex Concepts Simplified

Final Decision (28 U.S.C. § 1291): A district-court ruling that resolves all issues and claims so nothing remains but ministerial tasks.
Interlocutory Order: Any decision that does not end the litigation on the merits—usually not immediately appealable.
Settlement Enforcement Order: A court order requiring parties to comply with terms of a settlement agreement.
Federal Rule of Civil Procedure 21: Allows misjoined parties to be dropped from an action without prejudice.
Federal Rule of Civil Procedure 41(a)(2): Governs voluntary dismissal of an action by court order, typically with terms.

Conclusion

The Eleventh Circuit’s ruling in Hill v. Clayton County underscores that a settlement enforcement order which leaves significant claims pending and contemplates further amendments is not a final decision under § 1291. Parties cannot obtain appellate review until the district court disposes of all claims or enters judgment. This decision clarifies a narrow but important aspect of finality doctrine: if you want to immediately appeal enforcement of a settlement, make sure the district court closes the case entirely.