The Appellate Group

Rain International LLC v. Drockton

Rain International LLC v. Drockton, 2021 UT App 68 (per curiam)

Appellate Jurisdiction

A district court entered a judgment for attorney fees against the defendant for failing to comply with discovery obligations. The district court certified the attorney fee judgment as a final judgment under Utah R. Civ. P. 54(b). The Utah Court of Appeals dismissed, holding:

  • The court of appeals has no jurisdiction to decide this case. A judgment for attorney fees awarded as a discovery sanction is not a “claim for relief” under Rule 54(b), so that judgment cannot be certified as final and appealable under Rule 54(b).

Read the full court opinion