Hyde v. Irish

Docket: 15-13010

Opinion Date: June 17, 2020

Judge: Thapar

Areas of Law: Civil Procedure

The Eleventh Circuit joined its sister circuits in holding that a district court may address a sanctions motion based on its inherent powers or 28 U.S.C. 1927 even if it lacks jurisdiction over the underlying case. The court explained that these sanctions, like Rule 11 sanctions, do not require a court to rule on the merits of the underlying case. Furthermore, the purpose of the sanctions outlasts the end of the case. In this case, the court held that the district court did not abuse its discretion by denying defendant's motion for sanctions, because defendant failed to make a showing of bad faith. Defendant's only exhibit submitted to show bad faith could be interpreted in more than one way, and the district court also considered defendant's nearly three-year delay in bringing his sanctions motion.