On January 30, 2015, in Jones v. Association of Flight Attendants-CWA, the US Court of Appeals for the Seventh Circuit dismissed an appeal for lack of jurisdiction because the magistrate judge who issued the purported final judgment acted outside the scope of his authority by issuing a dispositive ruling (No. 14-1482, (7th Cir. Jan. 30, 2015)).

In 2010, Vernon Jones was fired for misconduct during his employment as a flight attendant for United Airlines. He filed suit in the Northern District of Illinois against the union that had represented him during his employment for failing to fairly represent him in his bid to keep his job. The parties consented to have a magistrate judge preside over the case and ultimately agreed to a settlement in which the union agreed to file on Jones's behalf a grievance challenging his termination under the National Labor Relations Act. In return, Jones agreed to dismiss the lawsuit against the union with prejudice. In June 2013, both parties signed a stipulation of dismissal under FRCP 41, without providing for continuing jurisdiction in federal court.

Jones subsequently filed three pro se submissions attempting to undo the settlement and reinstate the case. The clerk directed the submissions to the magistrate judge. The magistrate judge dismissed each by issuing three minute orders. In the third minute order, the magistrate denied Jones's "motion to establish court's jurisdiction" for lack of subject matter jurisdiction, explaining that the court could not exercise jurisdiction over a case that had been dismissed with prejudice. Jones appealed.

In reviewing the magistrate's order, the Seventh Circuit first noted that a magistrate judge who enters a final judgment by consent may dispose of post-judgment motions in the same litigation. The Seventh Circuit found that the magistrate judge correctly concluded that the third submission was not a FRCP 60(b) post-judgment motion. However, it also found that Jones's motion was an attempt to bring a new lawsuit for breach of contract to enforce the settlement agreement, which was not covered by the parties' prior consent to the magistrate's jurisdiction. As a result, the magistrate judge did not have the authority to issue a dispositive ruling on the motion under 28 U.S.C. § 636(c), rendering the purported final decision on Jones's motion a nullity. The Seventh Circuit therefore concluded that the case was still pending before the district court, and that it lacked jurisdiction to hear the appeal.