Post-Judgment Sanctions — Necessity of Separate Notice of Appeal

From Keck Garrett & Assocs., Inc. v. Nextel Commc’ns, Inc., 2008 U.S. App. LEXIS 3649 (7th Cir. Feb. 21, 2008):

To the extent that Keck Garrett is attempting to appeal this matter, we are without jurisdiction. Keck Garrett filed a motion for sanctions in the district court, but, insofar as the record before us indicates, the district court still has the matter under advisement. A district court's decision on a post-judgment Rule 11 motion is a separate judgment that requires the filing of a separate notice of appeal. Leahy v. Bd. of Trs., 912 F.2d 917, 923 (7th Cir. 1990); see also Cassidy v. Cassidy, 950 F.2d 381, 382 (7th Cir. 1991) (holding that decisions on the merits and post-judgment decisions on Rule 11 sanctions are separately appealable; until the district court "wraps up" the post-judgment Rule 11 issue, "there is no final and appealable decision").

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