nonfinal. Id. at 1268. Instead, Rekstad held that the decision as to whether an ERISA remand order is final should be made on a case-by-case basis. Id. UNUM agrees with Metzger that the remand order was not a final judgment. It further argues that even if the remand order was a final judgment, the district court had jurisdiction over Metzger’s sanction motion pursuant to its continuing jurisdiction to enforce its own orders and judgments. We agree with this latter proposition, and therefore express no opinion as to whether the remand order was itself a final judgment. As a general rule, even after a district court has entered judgment, it retains ancillary jurisdiction to enforce its own orders and judgments. Peacock v. Thomas, 516 U.S. 349, 856, 116 S.Ct. 862, 133 L.Ed.2d 817 (1996) (<HOLDING>); Kokkonen v. Guardian Life Ins. Co. of Am.,
recognizing courts inherent power to issue subpoenas recognizing the inherent power of the courts to issue warrants recognizing inherent power of courts of appeals recognizing the inherent power of indian tribes  to exercise criminal jurisdiction over all indians recognizing use of ancillary jurisdiction in subsequent proceedings for the exercise of the courts inherent power to enforce its judgments