Mitchell v. Lyons Professional Servs., Inc., No. 10-5100 (2d Cir. 2013)Annotate this Case
Appellants appealed the denial of their motion for a writ of execution against Garrison Services. The motion was based on default judgments appellants had earlier obtained against Lyons. The court denied the motion as a sanction for appellants' counsel's repeated failures to comply with the court's orders. The court held that although the district court had an adequate basis to sanction counsel and accorded the required procedural safeguards, further findings were needed to support a sanction that fell entirely on the clients rather than principally on the lawyer.