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.