William Hubbs Rehnquist, Willy v. Coastal Corporation — Opinion of the Court (1992)
“ The challenge in that case was to an order imposing Rule 11 sanctions for filing a frivolous complaint, entered [p. 138] after the plaintiff had voluntarily dismissed his action. In the course of our discussion we noted that " [i] t is well established that a federal court may consider collateral issues after an action is no longer pending.... [An] imposition of a Rule 11 sanction is not a judgment on the merits of an action. Rather, it requires the determination of a collateral issue: whether the attorney has abused the judicial process, and, if so, what sanction would be appropriate." ”
