Why is the case important?
The Hallocks’ computer software was destroyed by Government agents during an investigation, and was subsequently bared from bringing suit against the Government and the agents for these torts.
Facts of the case
U.S. Customs Service agents investigating a child pornography website raided Susan and Richard Hallock’s residence and seized several computers. The Hallocks were cleared of any guilt, but the computers were damaged beyond repair. Susan Hallock originally sued the government under the Federal Tort Claims Act (FTCA), which waives the government’s sovereign immunity in certain cases. The District Court dismissed that case for lack of jurisdiction, because the FTCA’s waiver has an exception for claims arising from the detention of goods by customs. Hallock then sued Will and the other customs agents as individuals. The agents made a motion for dismissal under a provision of the FTCA that bars suits where a judgment on the claim has already been entered. The District Court denied the motion, accepting Hallock’s argument that the dismissal for lack of jurisdiction did not constitute a final judgment. Although the trial had not yet concluded, the Second Circuit Court of Appeals granted the agents’ appeal of the District Court’s ruling on the motion and affirmed the District Court, ruling that since Hallock had not properly brought a claim in the original suit, no judgment had been entered. The Circuit Court ruled that it had jurisdiction to hear the appeal under the collateral order doctrine, under which some decisions of lower courts other than final judgments can be appealed. The Supreme Court granted certiorari on the question of the motion to dismiss, but instructed the parties to argue the question of the Circuit Court’s authority to hear the appeal.
Whether refusal to apply the judgment bar of the Federal Tort Claims Act is open to a collateral appeal.
“Three conditions are required for collateral appeal: the order must  conclusively determine the disputed question,  resolve an important issue completely separate from the merits …, and  be effectively unreviewable on appeal from a final judgment.PAlthough the statutory judgment bar is arguably broader than traditional res judicata, it functions in much the same way, with both rules depending on a prior judgment as a condition precedent The concern behind both rules is a different one, of avoiding duplicative litigation, “”multiple suits on identical entitlements or obligations between the same parties.”” But this rule of respecting a prior judgment by giving a defense against relitigation has not been thought to protect values so great that only immediate appeal can effectively vindicate them. Absent particular reasons for discretionary appeal by leave of the trial court, a defense of claim preclusion is fairly subordinated to the general policy of deferring appellate review to the moment of final judgment.””
- Case Brief: 2006
- Petitioner: Richard Will et al.
- Respondent: Susan Hallock et al.
- Decided by: Roberts Court
Citation: 546 US 345 (2006)
Granted Jun 6, 2005
Argued: Nov 28, 2005
Decided: Jan 18, 2006