Sanctions — § 1927 — Post-Judgment Jurisdiction

The Fifth Circuit upheld the imposition of § 1927 sanctions more than a year after the frivolous lawsuit had been dismissed (the plaintiff sued the wrong doctor) in Ratliff v. Gibson, 2007 U.S. App. LEXIS 28664 (5th Cir. Nov. 13, 2007). Looking to Rule 11 precedent, Circuit Judge Jerry E. Smith wrote for the Court that: “Requests for attorneys' fees and expenses under § 1927 — like those under rule 11 — are ... part of a court’s collateral jurisdiction.”

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