The "final judgment rule does not require district courts to calculate the precise amount of damages in every case." S.E.C. v. Carrillo, 325 F.3d 1268, 1272 (11th Cir. 2003) (per curiam). "This is true even though it might appear that the district court still has something left to do that goes beyond executing the judgment."
As a result the determination of the interest amount was not a ministerial task. See S.E.C. v. Carrillo, 325 F.3d 1268, 1272 (11th Cir. 2003) ("[I]f the judgment amount, the prejudgment interest rate, or the date from which prejudgment interest accrues is unclear, the calculation of prejudgment interest is no longer a ministerial act and the court's order is not final."). The School District's challenge is, in any event, meritless.
As the Supreme Court has observed, the “policy” underpinning § 1291 “is inimical to piecemeal appellate review of trial court decisionswhich do not terminate the litigation, and ... this policy is at its strongest in the field of criminal law.” United States v. Hollywood Motor Car Co., 458 U.S. 263, 265, 102 S.Ct. 3081, 3082, 73 L.Ed.2d 754 (1982); see also SEC v. Carrillo, 325 F.3d 1268, 1272 (11th Cir.2003) ( “Although the ‘final judgment rule’ serves many purposes, one of its central objectives is to ensure that this court does not engage in piecemeal appellate review.”). So, too, the policy underpinning § 3742. In his brief on appeal, Muzio challenged the sentenced imposed on June 30, 2010, on these grounds:
"[W]e must evaluate our appellate jurisdiction sua sponte even if the parties have not challenged it." S.E.C. v. Carrillo, 325 F.3d 1268, 1271 (11th Cir. 2003).
In addition, the decision to grant prejudgment interest on the disgorgement amount, as well as the rate at which interest was awarded, fell squarely within the discretion of the district court. S.E.C. v. Carrillo, 325 F.3d 1268, 1269, 1273 (11th Cir. 2003).
The May 15 order is silent as to an award of any prejudgment interest, including the prejudgment interest rate and the date from which any prejudgment interest would accrue. See U.S. S.E.C. v. Carrillo, 325 F.3d 1268, 1272-74 (11th Cir. 2003) (noting that the calculation of prejudgment interest can be ministerial, but if the judgment amount, the prejudgment interest rate, or the date from which prejudgment interest accrues is unclear, the calculation of prejudgment interest is no longer a ministerial act and the court's order is not final); Osterneck v. Ernst & Whinney, 489 U.S. 169, 176 n.3 (1989) (indicating that prejudgment interest is part of the "merits" of a case). Additionally, the May 15 order is not immediately reviewable under the collateral order doctrine because it is not effectively unreviewable on appeal from a final judgment. See Plaintiff A v. Schair, 744 F.3d 1247, 1253 (11th Cir. 2014) (explaining that a ruling that does not conclude the litigation may be appealed under the collateral order doctrine if it, inter alia, is "effectively unreviewable on appeal from a final judgment").
Accordingly, the district court's failure to decide the amount of prejudgment interest meant that Halo's infringement claim had not been fully adjudicated. See also Dieser v. Continental Casualty Co., 440 F.3d 920, 922-24 (8th Cir. 2006); SEC v. Carrillo, 325 F.3d 1268, 1271-74 (11th Cir. 2003); Com. Union Ins. Co. v. Seven Provinces Ins. Co., 217 F.3d 33, 36-37 (1st Cir. 2000). Furthermore, to conclude otherwise would mean that our earlier dismissal of Pulse's prejudgment interest appeal was improper.
That order, entered on the docket sheet, resolved all issues on the merits and left only ministerial calculations, so it was a final decision. See Republic Nat. Gas Co. v. Oklahoma, 334 U.S. 62, 68 (1948) ("[I]f nothing more than a ministerial act remains to be done, such as the entry of a judgment upon a mandate, the decree is regarded as concluding the case and is immediately reviewable."); Meade Instruments Corp. v. Reddwarf Starware, LLC, No. 1999-1517, 2000 WL 987268, at *3 (Fed. Cir. June 23, 2000); U.S. S.E.C. v. Carrillo, 325 F.3d 1268, 1272 (11th Cir. 2003) (per curiam); Goodwin v. United States, 67 F.3d 149, 151 (8th Cir. 1995); see also Budinich v. Becton Dickinson & Co., 486 U.S. 196 (1988) (holding that merits ruling can be "final decision" even if attorney's fees issues remain). An appeal was permitted under 28 U.S.C. § 1295(a)(1) and Federal Rule of Appellate Procedure 4, whether because no separate document beyond the December 2019 order was required under Federal Rule of Civil Procedure 58 or because waiting for the separate document (which was eventually entered in March 2020) is not required for a valid appeal (validity depending on finality).
Relatedly, the decision to grant prejudgment interest—and the rate at which interest is awarded—falls squarely within the discretion of the district court. SEC v. Carrillo, 325 F.3d 1268, 1273 (11th Cir. 2003). On appeal, Hall fails to prove that the district court was acting outside of its discretion in imposing the prejudgment interest amount.
Federal courts of appeals generally have jurisdiction to review only the final decisions of lower federal courts. 28 U.S.C. § 1291; S.E.C. v. Carrillo, 325 F.3d 1268, 1272 (11th Cir. 2003).