Dfi Properties LLC v. Gr 2 Enterprises LLC, 242 P.3d 781

GR 2 Enterprises and DFI Properties disputed possession of Utah real property in an unlawful detainer action.
During proceedings, a GR 2 owner engaged in NATO Nation filings; the district court found the filings frivolous and sanctionable under Rule 11.
The district court struck GR 2's answer and counterclaims, and entered default judgment against GR 2, ordering restitution of the property to DFI.
The district court reserved issues of attorney fees and treble damages for later determination, indicating supplementation would be needed to award amounts.
GR 2 appealed the judgment, but the court dismissed for lack of appellate jurisdiction because the judgment was nonfinal pending awards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the appeal from a final judgment?	GR 2 contends judgment is final and appealable.	DFI contends the judgment is nonfinal because it reserves attorney fees and treble damages for later determination.	Nonfinal; appellate jurisdiction lacking; appeal dismissed.
Was the district court's Rule 11 sanction appropriate or reviewable on appeal?	GR 2 challenges sanction mechanics and due process under Rule 11.	DFI maintains sanctions were proper given frivolous filings; issues moot due to lack of finality.	Not reached on the merits; court lacks jurisdiction due to nonfinal judgment.

Anderson v. Wilshire Invs., LLC, 2005 UT 59 (2005 UT 59) (finality and appealability of judgments; exceptions under Rule 3(a))
Irvin v. State (State ex rel. S.M.), 154 P.3d 787 (2006 UT 75) (court determines finality and appealability of orders)
Loffredo v. Holt, 37 P.3d 1070 (2001 UT 97) (finality rule and limitations on piecemeal appeals)
ProMax Dev. Corp. v. Raile, 998 P.2d 254 (2000 UT 4) (attorney fees and finality considerations in judgments)
Bradbury v. Valencia, 5 P.3d 649 (2000 UT 50) (finality rule; exceptions and procedure for final judgments)