No Rule 54(b) Certification Where Adjudicated and Pending Claims Are “Intertwined”

 In two separate cases, the Court of Civil Appeals dismissed Rule 54(b) appeals from partial summary judgments. Certification under Rule 54(b) was improper in both cases because the appealed claims were too closely “intertwined” with claims that remained pending. Holman v. Sims, No. 2080809 (Ala. Civ. App. Jul. 16, 2010); Marshall Auto Painting & Collision, Inc. v. Peach Auto Painting & Collision, Inc., No. 2090090 (Ala. Civ. App. Jul. 16, 2010).

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