Supreme Court of the United States
Willy v. Coastal Corp.
March 3, 1992503 U.S. 131
Summary
Chief Justice Rehnquist delivered the unanimous opinion affirming the Rule 11 sanctions. The Federal Rules authorize sanctions for misconduct in district court even when the court is later determined to lack subject-matter jurisdiction. Such sanctions are collateral to the merits and do not violate Article III because they enforce procedural obligations rather than adjudicate the underlying dispute. The Court distinguished coercive civil contempt orders and did not reach whether inherent judicial powers independently supported the sanctions. There were no separate opinions.
Holding
- Authority under the Federal Rules to impose sanctions despite a subsequent determination that subject-matter jurisdiction was absent.. The Federal Rules authorize Rule 11 sanctions in the circumstances presented notwithstanding the later determination that the district court lacked subject-matter jurisdiction.
- Article III limits on Rule 11 sanctions when the district court lacked subject-matter jurisdiction.. Article III does not invalidate the Rule 11 sanctions imposed here, even though the sanctioned party successfully challenged subject-matter jurisdiction.
Docket 90-1150
Cited authorities
- Rule 11 of the Federal Rules of Civil Procedure
- 28 U.S.C. § 1441
- Rule 81(c)
- 28 U.S.C. §§ 1331
- 28 U.S.C. § 2072
- 28 U.S.C. § 1919
- 28 U.S.C. § 1447
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