Summary

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."
Source: Wikisource

William Hubbs Rehnquist Willy v. Coastal Corporation — Opinion of the Court (1992)

Courts do make mistakes; in cases such as Catholic Conference it may be possible immediately to seek relief in an appellate tribunal. But where such an immediate appeal is not authorized, there is no constitutional infirmity under Article III in requiring those practicing before the courts to conduct themselves in compliance with the applicable procedural rules in the interim, and to allow the courts to impose Rule 11 sanctions in the event of their failure to do so.
Source: Wikisource

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