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Precedent Regarding Postjudgment Filing of Motions for Sanctions Clarified

In Huggins v. Lueder, Larkin & Hunter, LLC, the United States Court of Appeals for the Eleventh Circuit addressed whether a Rule 11 motion for sanctions may be filed after the issuance of a final judgment. On appeal, the Eleventh Circuit vacated the district court’s denial of a law firm’s postjudgment motion for sanctions against opposing counsel. The court resolved seemingly conflicting precedent by holding that postjudgment sanctions motions are permissible so long as the final judgment does not prematurely end the twenty-one-day safe harbor period.

Luther H. Wolff IV, Huggins v. Leuder, Larkin & Hunter, LLC, 4 Cumb. L. Rev. Online 96 (2023).


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