Missouri Court of Appeals, Western District / Sep 1, 2020
Emily Riegel, et al., vs. Nicole Forsythe
Attorney Nicole Forsythe appealed a circuit court's judgment imposing $10,000 in sanctions against her for bad faith conduct related to a confidentiality order in an underlying wrongful death action. Forsythe argued the judgment was appealable under the collateral-order doctrine or as a final judgment. The appellate court dismissed the appeal for lack of jurisdiction, holding that an order for monetary sanctions against an attorney is not a "claim" and thus not a "final judgment" under Missouri law, and declining to adopt the collateral-order doctrine.