Sanctions and Due Process

The district court in Williams v. Biomedical Research Foundation imposed a sanction for what it saw as an “impertinent” email to its law clerk. The Fifth Circuit reversed, noting: “The district judge signaled his intent to sanction Plante-Northington for the first time at an oral hearing on an unrelated matter. He then imposed the sanctions just minutes later at that hearing. Plante-Northington was allowed to utter only a few sentences in her defense before she was cut off. More importantly, she was given no advance notice sufficient for preparing a written or oral submission in response to the contemplated sanctions.” No. 22-30064 (Aug. 24, 2022) (unpublished).