May a Petition Seeking Rule 137 Sanctions Be Filed Prior to Final Judgment ?

In Kellett v. Roberts, 276 Ill. App. 3d 164, 213 Ill. Dec. 26, 658 N.E.2d 496 (1995), the court rejected the argument that a petition seeking Rule 137 sanctions was premature because it was filed prior to final judgment. Examining the language of the rule, including recent amendments, the court concluded that a motion for sanctions is timely if filed "within the relevant cause of action." Kellett, 276 Ill. App. 3d at 171. The court believed that preventing parties from bringing sanction motions during the relevant cause of action would be inconsistent with the purpose of Rule 137, "to provide a plain, efficient, and speedy remedy." Kellett, 276 Ill. App. 3d at 171.