A motion for sanctions asks the court to penalize a party or attorney for misconduct during litigation — discovery abuse, frivolous filings, or violating a court order — with consequences ranging from fee-shifting to dismissal of claims.
Tie the request to a specific rule or order
Sanctions motions are strongest when tied to a specific violated rule or court order, rather than a general claim of bad faith — courts want a clear basis in the rules, not just frustration with the other side's conduct.
Document the pattern, not just one incident
A single missed deadline rarely justifies serious sanctions. A documented pattern — repeated discovery violations, ignored court orders, escalating bad conduct — makes a far stronger record for meaningful relief.
Many rules require a warning first
Some sanctions frameworks (like safe-harbor provisions for frivolous filings) require giving the other side notice and a chance to correct the problem before the motion can be filed — skipping this step can get the motion denied on procedural grounds alone.
Ask for a specific, proportionate remedy
Requesting a remedy proportionate to the misconduct — fees for a specific wasted motion, rather than case-ending sanctions for a minor violation — is both more likely to be granted and harder for the other side to characterize as overreach.