MCR 2.114(E) Interpretation

MCR 2.114(E) provides that if a document is signed in violation of the requirements of the rule, the court shall impose an appropriate sanction on the person who signed the document. The sanction "may include an order to pay to the other party or parties the amount of the reasonable expenses incurred because of the filing of the document, including reasonable attorney fees." In Ramsey, the plaintiff was sanctioned because he filed a "delayed" motion for rehearing after the then-existing seven-day time limit for such motions had expired. Id. at 535-536. The trial court deemed the motion frivolous because it was untimely and awarded costs pursuant to MCR 2.114(E). Id.