Seventh Circuit: Bennie Kennedy v. Schneider Electric

Impeachment evidence against claims of opposing witnesses did not rise to the clear and convincing level of deliberate perjury required for fraud on the court; they should have been raised on direct appeal or in a post-judgment motion.

Rule 11 sanctions upheld, as delay in filing couldn't be ascribed to a reluctance to assert such a thing against opposing counsel.

Motion for appellate sanctions needs to be raised in a separate motion; they can't just be mentioned in the briefing.

http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2018/D06-19/C:17-1786:J:Hamilton:aut:T:fnOp:N:2173108:S:0