Second Circuit -- SEC v. Lynn A. Smith, et al.

No appeal possible for Rule 11 sanctions under collateral order doctrine, as not nonreviewable, and they implicate the merits of the underlying action.

Court can, however, hear challenge to sanction against a trustee where inextricably intertwined with an injunction.

Sufficient evidence for sanctions against trustee.

SEC v. Lynn A. Smith, et al.