There is some confusion in the case law as to whether there is a split in the Circuits concerning whether § 1927 authorizes the imposition of sanctions on pro se litigants, as reflected, e.g., in the recent decision in Wallace v. Kelley, 2007 U.S. Dist. LEXIS 56472 (D. Neb. Aug. 1, 2007), which (i) cites Alexander v. United States, 121 F.3d 312, 316 (7th Cir. 1997) for the proposition that there is a split in the circuits on this issue and proceeds to (ii) conclude that § 1927 does authorize sanctions on pro se litigants. This was harmless error in Wallace because the Court also imposed sanctions under a clearly-apt alternative authority, the inherent power of the court. But it was error. No case has ever attempted to reconcile the text of § 1927 with the notion that the statute authorizes imposing sanctions on pro se litigants. It does not. The purported conflict in the Circuits on this issue is not well grounded. It ultimately rests on the Ninth Circuit opinion in Wages v. IRS, 915 F.2d 1230, 1235-36 (9th Cir. 1990), which misread the same court’s earlier decision in Wood v. Santa Barbara Chamber of Commerce, Inc., 699 F.2d 484, 485-86 (9th Cir. 1983), as permitting the imposition of § 1927 sanctions on pro se litigants. Not so. Wood is in fact very clear that the litigant before it was represented and that sanctions were imposed jointly on both the client (the plaintiff) — under Federal Rule of Appellate Procedure 38 — and his counsel, under 28 U.S.C. § 1927, jointly in the sum of $10,000. The Seventh Circuit in Alexander (cited in Wallace) in turn cited Wages for the existence of a conflict among the Circuits when Wages is really just an errant Ninth Circuit decision that conflicts with the same court’s post-Wood decision in Zaldivar v. City of Los Angeles, 780 F.2d 823, 831 (9th Cir. 1986) (which recognizes that § 1927 does not authorize the imposition of sanctions on pro se litigants).