Systems Solutions of Kentucky LLC, v. DHL Express (USA), Inc., No. 21-2505 (7th Cir. 2022)Annotate this Case
Rankins, a DHL employee, was seriously injured at work when a cable within a winch system snapped. Rankins received workers’ compensation benefits. The winch system was designed and installed by SSK. Rankins brought products-liability claims in state court against SSK. DHL lost the physical pieces of the winch system after the suit was removed to federal court. SSK brought a third-party suit against DHL seeking damages for the spoliation of evidence and seeking contribution under the Illinois Joint Tortfeasor Contribution Act. DHL settled with Rankins by waiving its workers’ compensation lien ($455,229.17) and paying an additional $87,500. DHL then argued that its good-faith contribution settlement with Rankins entitled it under state law to a full dismissal of all third-party claims stemming from Rankins’s injury. The district court rejected SSK’s argument that the settlement did not compensate SSK for its own spoliation-related difficulties and dismissed SSK’s third-party complaint.
The court found that, under FRCP 54(b), there was no just cause for delaying SSK’s appeal of the dismissal of the spoliation claim. The Seventh Circuit dismissed the appeal for lack of jurisdiction. The spoliation and product liability claims are not factually and legally separable to the extent required by Rule 54(b), so there is no final judgment.