U.S. Court of Appeals for the First Circuit

Air-Con, Inc. v. Daikin Applied Latin America, LLC

August 21, 2026

Summary

The court dismissed the appeal for lack of appellate jurisdiction because the district court's judgment was not final under the final-judgment rule. A counterclaim dismissed voluntarily without prejudice could be revived in the same district court, so the dismissal did not create a genuinely final judgment, and no authorized route for interlocutory review was available. The court held that this rule applies whether the dismissed claim belonged to the would-be appellant or appellee.