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District Court’s Failure to Adjudicate Qualified Immunity “At the Earliest Possible Stage in the Litigation” Subject to Appeal Under Collateral-Order Doctrine, Holds Fifth Circuit

In Wertenbroch v. Hardeman, No. 25-40616 (5th Cir. June 3, 2026), the Fifth Circuit holds that even a non-response by a district court to a motion for qualified immunity can serve as an “implicit denial . . . that is immediately appealable under the collateral-order doctrine.” Plaintiffs sued the City Manager of Pittsburg, Texas for…

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Divided Sixth Circuit Panel Queries Diversity Jurisdiction in Case Against a Lloyd’s of London “Syndicate” of Underwriters

In Halbower v. Hiscox Syndicate 33 of Lloyd’s of London, No. 25-1152 (6th Cir. May 29, 2026), the panel unanimously remands an insurance dispute to reconsider diversity jurisdiction where the defendant is a Lloyd’s of London “Syndicate,” an unincorporated group of underwriting members. The panel, nevertheless, splits over the proper analysis. Syndicates are loose associations…

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“Administrative Termination” of a Post-Judgment Motion Did Not “Dispos[e] Of” It for Fed. R. App. P. 4(a)(4)(A) Tolling Purposes, Holds Eleventh Circuit

In Khatabi v. Car Auto Holdings LLC, No. 24-12573 (11th Cir. May 28, 2026), the Eleventh Circuit holds that the “administrative termination” of a Fed. R. Civ. P. 50 and 59 motions to facilitate a post-trial mediation was not sufficiently conclusive to restart the 30-day clock for filing an appeal under Fed. R. App. P.…

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