the Ninth Circuit has already expanded Cunningham beyond Rule 37(a). In Cato v. Fresno City, 220 F.3d 1073, 1074 (9th Cir.2000), this court stated that the “reasons underlying Cunningham’s bar against immediate appeal from Rule 37(a) sanctions orders apply equally to Rule 16 sanctions orders.” Cato followed Cunningham, holding sanctions imposed under Rule 16(f) to be appealable only after final judgment has been entered, even when the attorney no longer represents any party in the case. Id. Similarly, in American Ironworks & Erectors, Inc. v. North American Constr. Corp., we interpreted Cunningham to bar immediate appeal of an interlocutory order granting attorney’s fees as a condition of substituting counsel. 248 F.3d 892, 897 (9th Cir.2001). We stated that “[although th st Cir.1986) (<HOLDING>). The law in the Second Circuit prior to
holding that denial of counsel in section 1983 action is not immediately appealable holding sanctions order pursuant to district courts inherent powers not immediately appealable holding sanctions pursuant to rule 26g not immediately appealable holding an order of rule 37a sanctions against an attorney is immediately appealable under  1291 holding that the denial of a motion to remand is interlocutory and not immediately appealable