Leonardo Crespo v. TSLA - Non-Precedential Court Opinion

11th Circuit Published Opinions (CourtListener)

Filed March 19th, 2026

Detected March 19th, 2026

Summary

The 11th Circuit Court of Appeals dismissed an appeal in Leonardo Crespo v. TSLA for lack of jurisdiction. The court found the appealed order was not final and therefore not immediately appealable, and a subsequent final judgment did not cure the premature appeal.

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What changed

The Eleventh Circuit Court of Appeals has dismissed the appeal in Leonardo Crespo v. TSLA, docket number 25-12932. The dismissal, issued sua sponte, was based on a lack of appellate jurisdiction. The court determined that the district court's order denying the motion to enforce the defendants' demand for a jury trial was not a final order as it did not conclude the litigation on the merits, nor was it otherwise immediately appealable under the collateral order doctrine.

This ruling means that the appeal was dismissed because it was filed prematurely. The court noted that while a subsequent entry of final judgment can sometimes cure a premature appeal, this is only applicable when the appeal is from an otherwise final order. The dismissal has no direct compliance implications for regulated entities, but it serves as a reminder for legal professionals regarding the finality requirements for appeals in federal court.

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March 19, 2026 Get Citation Alerts Download PDF Add Note

Leonardo Crespo v. TSLA

Court of Appeals for the Eleventh Circuit

Citations: None known
Docket Number: 25-12932
Precedential Status: Non-Precedential
Nature of Suit: NEW
Opinion
Authorities (3)
Cited By (0)
Summaries (0)
Similar Cases (0)
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Combined Opinion

USCA11 Case: 25-12932 Document: 8-1 Date Filed: 03/19/2026 Page: 1 of 2

NOT FOR PUBLICATION

In the
United States Court of Appeals
For the Eleventh Circuit

No. 25-12932
Non-Argument Calendar

LEONARDO CRESPO,
Plaintiﬀ-Appellant,
versus

TESLA, INC.,
a foreign corporation,
TESLA FLORIDA, INC.,
a Florida corporation,
Defendants-Appellees.

Appeal from the United States District Court
for the Southern District of Florida
D.C. Docket No. 9:25-cv-80129-DMM

Before JILL PRYOR, LAGOA, and ABUDU, Circuit Judges.
PER CURIAM:
USCA11 Case: 25-12932 Document: 8-1 Date Filed: 03/19/2026 Page: 2 of 2

2 Opinion of the Court 25-12932

This appeal is DISMISSED, sua sponte, for lack of
jurisdiction. Leonardo Crespo, pro se, appeals from the district
court’s order denying his motion to enforce the defendants’
demand for a jury trial. While this appeal was pending, the district
court entered final judgment.
The appealed order is not final because it did not end the
ligation on the merits. 28 U.S.C. § 1291; CSX Transp., Inc. v. City of
Garden City, 235 F.3d 1325, 1327 (11th Cir. 2000) (explaining that a
final judgment leaves nothing for the district court to do but
execute the judgment). Crespo’s amended complaint remained
pending when the order was entered. And the order is not
otherwise immediately appealable. See Howard v. Parisian, Inc., 807
F.2d 1560, 1566-67 (11th Cir. 1987) (holding that an interlocutory
order denying a jury trial in a civil action is not reviewable under
the collateral order doctrine). Nor does the subsequent entry of
final judgment cure Crespo’s premature appeal. See Robinson v.
Tanner, 798 F.2d 1378, 1382-83 (11th Cir. 1986) (explaining that a
subsequent final judgment cures a premature appeal only when the
appeal is from an otherwise final order dismissing a claim or party).
All pending motions are DENIED as moot.