Sanctions — If Only Appellate Challenge Is to District Court’s Jurisdiction to Award Sanctions, Review Is De Novo, Not Abuse of Discretion — District Court Has Jurisdiction to Issue Post-Judgment, Inherent Power Sanctions

Haagensen v. Reed, 2016 U.S. App. LEXIS 20473 (3d Cir. Nov. 15, 2016): OPINION1 1   This disposition is not an opinion of the full court and pursuant to I.O.P. 5.7 does not constitute binding precedent. In 2006, Janice Haagensen, as personal representative of her mother's estate, initiated a quiet title action in the Court of Common Pleas of Lawrence County, Pennsylvania. The state court ruled ...

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