Due to a SCOTUS decision about 10 years ago (Cunnignham v. Hamilton County), immediate appeals of sanctions are now foreclosed, with the exception of one circumstance - this case doesn't meet that circumstance.
I am not sure that
Cunningham even applies here. In
Cunningham, the issue was whether sanctions imposed under
FRCP 37 could be appealed. However,
FRCP 37 addresses
discovery, and permits sanctions for failure to comply with
discovery rules. I think that is a very different situation than when Rule 11 sanctions are imposed after a case is dismissed.
While I can find many appeals of Rule 11 decisions through a Google search (including Phil Berg's appeal in 3rd District, which the Appellate Court ruled on earlier this year), I haven't yet found a case specifically addressing when Rule 11 Sanctions may be appealed. However, the very fact that there are so many - decided after
Cunningham was issued, leads me to
believe that an appeal is permissible in this situation.