Motion for Sanctions is Claim Which Can Preclude Appeal

The Illinois Supreme Court held that a defendant's motion for sanctions filed after the dismissal of a case amounted to a claim which precluded appellate jurisdiction. The Court noted that the order of dismissal did not include language from Illinois Supreme Court Rule 304(a) that there was no just reason for delaying an appeal and that the dismissal with prejudice of the action did not dispose of all "claims" once the defendant's motion for sanctions was pending. John G. Philips & Associates v. Brown, 197 Ill.2d 337, 757 N.E.2d 875 (2001)