Johnson v. Fankell

Johnson (plaintiff), fired from her job as a liquor-store clerk, sued state liquor board officials (defendants) under 42 U.S.C. section 1983 in Idaho state court; the officials sought summary judgment on qualified immunity grounds, the trial court denied it, and the officials pursued an interlocutory appeal to the Idaho Supreme Court, which dismissed the appeal under a state procedural rule barring interlocutory appeals from summary judgment denials as non-final orders, also holding the order was not independently appealable under section 1983. The U.S. Supreme Court granted certiorari to decide whether the interlocutory appeal should have been allowed.