Ethics

Ninth Circuit Invited to Sit En Banc Regarding Dischargeability of Disciplinary Costs

The Ninth Circuit again questions the Supreme Court’s ‘atextual’ analysis of Section 523(a)(7).
Court: 

No De Novo Review of Discovery Sanctions After the Reference Is Withdrawn

An adverse inference sanction for spoliation of evidence is reviewed for abuse of discretion by the district court after withdrawal of the reference.

Rule 11 Motion for Sanctions May Be Filed After Final Judgment, Eleventh Circuit Says

A motion for sanctions may be filed after judgment, as long as the 21-day safe harbor has elapsed before judgment.
Court: 

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