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Williams v. Midwest Employers Casualty Co

Sanctions orders are not themselves appealable final decisions, nor are they appealable collateral orders.

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The full case caption appears at the end of this opinion.

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This case arose out of a state law workers’ compensation claim. In 1989, Willie Williams brought a claim against SpartechFilms for workers’ compensation. Spartech Films had an excess indemnity policy issued by Midwest Employers CasualtyCompany (“Midwest”). In 1991, Spartech’s workers’ compensation payments to Mr. Williams ceased. Mr. Williams laterreceived a default judgment against Adams Plastics, Inc., from the Louisiana Office of Workers’ Compensation. AdamsPlastics did not pay the judgment. In 1997, Mr. Williams brought a direct action against Midwest as the insurer of AdamsPlastics to collect his default judgment. Midwest removed to federal court, where it then filed third-party demands againstSpartech Films and Adams Plastics, alleging that they failed to comply with the terms of their policies. Mr. Williams died in1998, and Jo Ann Williams (“Williams”) substituted in his place as plaintiff.

On June 7, 1999, Magistrate Judge Karen Hayes mediated a settlement between Williams and Midwest. After hours ofnegotiation, the parties drafted and signed a “Memorandum of Settlement Agreement” that included arrangements for paymentsby Midwest to Williams and assignments of rights by Williams to Midwest. Over the next month and a half, revised versions ofthe settlement agreement passed between the parties as disputes over the meaning of the agreed-to settlement intensified.During this time, Williams did not receive her insurance money from Midwest, even though Louisiana law requires an insurer “topay a settlement within thirty days after an agreement is reduced to writing,” [FOOTNOTE 1] and even though Wallace, in a letter to the court,had stated that Midwest had tendered the funds to Williams.

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