Melvin Gualberto Medina Martinez brought suit against his employer, Carnival Corp., in Florida state court, asserting negligence claims arising from injuries he sustained while working on a cruise ship. Carnival removed the suit to federal court and filed a motion to compel arbitration based on an arbitration provision in Martinez's employment contract. The district court granted the motion, dismissed as moot all other pending motions in the action and closed the case for administrative purposes. However, the district court's order did not explicitly dismiss the case. Martinez subsequently appealed.

On appeal, Carnival argued that the Eleventh Circuit lacked jurisdiction to hear Martinez's appeal because the district court's order was a non-appealable interlocutory order. Specifically, Carnival argued that because the district court had not dismissed the case, but only dismissed all pending motions and closed the case administratively, the order was not final.

The Eleventh Circuit disagreed with Carnival. In concluding that the district court's order was final and therefore appealable, the Eleventh Circuit examined two hypothetical scenarios:

Carnival argued that the district court's order was more akin to a stay of the proceedings because it did not expressly dismiss the case. However, the Eleventh Circuit looked at the practical effect of the district court's order, rather than the form, in determining its finality. It found that the district court's order ended the litigation on the merits and left nothing for the district court to do but execute its judgment. Although the Eleventh Circuit recognized that administratively closing a case is not the same as issuing a dismissal, it concluded that the district court's order was a final judgment that had the same effect as dismissing the case, and could therefore be appealed. The Eleventh Circuit then rejected the merits of Martinez's claim that the district court had erred in compelling arbitration.

Counsel must carefully evaluate the practical effect of any district court order that administratively closes a case, especially in the context of compelling arbitration. Counsel should be aware that orders that do not expressly dismiss a case may nonetheless be considered final judgments for purposes of filing an appeal.