Langrock Sperry & Wool, LLP v. Citigroup, No. 11-5085 (2d Cir. 2012)Annotate this Case
Langrock appealed, inter alia, from the district court's order requiring it to pay certain fees and costs incurred by Citigroup in connection with this action. Langrock was ordered to pay Citigroup as a sanction for filing opposition papers to Citigroup's motion to dismiss four days late, despite the fact that Langrock submitted a timely request for an extension of the filing deadline that the court later determined was supported by good cause. The court held that the district court abused its discretion by imposing a sanction of attorneys' fees without explicitly finding that Langrock acted in bad faith, and by sanctioning Langrock without affording the attorneys prior notice and an opportunity to be heard. Accordingly, the court reversed the district court's orders.