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Johnson v. Fankell
United States Supreme Court
520 U.S. 911 (1997)
Johnson (plaintiff) brought a federal civil rights action under 42 U.S.C. § 1983 in state court against state liquor board officials (defendants) after she was terminated from her employment as a liquor-store clerk. The officials filed for summary judgment on qualified immunity grounds, arguing they did not violate a clearly established law. The trial court denied the motion, and the officials filed an interlocutory appeal to the Idaho Supreme Court. The state supreme court dismissed the appeal based on a state procedural rule that prohibited interlocutory appeals from denials of summary judgment motions, because such rulings were not final orders. The state supreme court also held that the order was not appealable under 42 U.S.C. § 1983. The United States Supreme Court granted certiorari to determine if the interlocutory appeal was proper.
Rule of Law
Holding and Reasoning (Stevens, J.)
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