Hall, Elsa v Hall, Samuel

Elsa sought review of the 3rd Circuit decision that it had no jurisdiction over her appeal because two cases involving the parties had been consolidated under Rule of Civil Procedure 42(a) and one case remained open in the district court. The Court reversed. It held that under eh history of “consolidation” in an 1813 federal statute and precedent applying that statute, cases which are consolidated do not lose their separate identity and thus a final judgment in one case can be appealed even if other consolidated cases remain open and this meaning continues under Rule 42(a).