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Baez-Sanchez v. Sessions

Citations: 862 F.3d 638; 2017 WL 2927632Docket: No. 16-3784, No. 17-1438

Court: Court of Appeals for the Seventh Circuit; July 10, 2017; Federal Appellate Court

Narrative Opinion Summary

This case involves the Seventh Circuit Court's emphasis on the criticality of adherence to jurisdictional statement requirements in appeals and briefs, as governed by Federal Rules of Appellate Procedure (FRAP) 28 and Seventh Circuit Rules. The appellant is required to provide detailed jurisdictional information, including statutory bases, relevant dates for timeliness, and the finality of orders. The court highlights specific challenges in ensuring compliance, particularly with interlocutory appeals and the collateral order doctrine. Appellees are tasked with reviewing appellants' summaries to confirm accuracy and completeness, especially concerning federal question and diversity jurisdiction. The court identified deficiencies in two separate cases, Baez-Sanchez v. Sessions and Bishop v. Air Line Pilots Association, where jurisdictional statements were either incomplete or required further verification. The court mandated the striking of non-compliant briefs and instructed the parties to resubmit corrected versions within a specified timeframe. This directive aims to rectify ongoing issues with jurisdictional compliance and ensure the jurisdiction of federal courts is properly established.

Legal Issues Addressed

Appellant's Jurisdictional Responsibilities

Application: Appellants must provide detailed jurisdictional information, including constitutional or statutory provisions and relevant dates, to verify the appeal's timeliness and finality.

Reasoning: The jurisdictional statement, as outlined in FRAP 28(a)(4), must include: 1) the basis for the district court or agency’s jurisdiction; 2) the basis for the appellate court’s jurisdiction; 3) relevant dates to demonstrate timeliness of the appeal or petition; and 4) information establishing finality or exceptions to the final-judgment rule.

Appellee's Jurisdictional Review

Application: Appellees must verify the completeness and accuracy of the appellant's jurisdictional summary and address any deficiencies, especially in federal question and diversity cases.

Reasoning: For the appellee's jurisdictional statement, it is generally less extensive but equally critical. Under FRAP 28(b), the appellee must indicate if the appellant's jurisdictional summary is complete and correct.

Consequences of Non-Compliance with Jurisdictional Requirements

Application: Non-compliance with jurisdictional requirements results in briefs being stricken and necessitates resubmission to adhere to FRAP 28(a) and Circuit Rule 28(a).

Reasoning: The briefs from both Sessions and the Air Line Pilots Association were stricken, and they are required to submit new briefs within seven days, ensuring adherence to all relevant jurisdictional requirements.

Interlocutory Appeals and Collateral Order Doctrine

Application: Counsel must provide adequate information when an appeal arises from a non-final order, including unresolved claims and applicability of the collateral order doctrine.

Reasoning: If the appeal arises from a non-final order that does not resolve all claims for all parties, counsel must provide necessary information to assess the order's appealability.

Jurisdictional Statements in Appeals

Application: The court requires complete and accurate jurisdictional statements in docketing and briefs as per Seventh Circuit Rules and FRAP 28, highlighting the need for specific jurisdictional information.

Reasoning: The court emphasizes the importance of proper jurisdictional statements in appeals and briefs, as required by Seventh Circuit Rules 3(c)(1) and 28(a).