Isaacson v. Manty, No. 12-2384 (8th Cir. 2013)
Annotate this CasePlaintiff appealed the bankruptcy court's imposition of sanctions on her for making factually unsupported and harassing statements in documents filed with the court. The court concluded that Federal Rule of Bankruptcy Procedure 9011 did not authorize the sanctions imposed in this case; even if Rule 9011 was inapplicable, it did not mean that the bankruptcy court lacked authority to sanction plaintiff; the court had jurisdiction over the appeal where the penalty imposed was criminal in nature because the monetary penalty was punitive, payable to the court, and non-compensatory; plaintiff did not move for recusal or object to the judge's participation and she therefore forfeited any objection; the bankruptcy court did not commit an obvious error by failing to recuse sua sponte and there was no showing of prejudice or miscarriage of justice; there was no reasonable probability of a different outcome before a different judge where the evidence of plaintiff's contempt was undisputed and aggravated; and plaintiff's remaining claims about the contempt process were without merit. Accordingly, the court affirmed the judgment.
Court Description: Civil case - Bankruptcy. In an appeal of an order imposing sanctions against Isaacson for making factually unsupported and harassing statements in documents filed with the bankruptcy court, the bankruptcy court erred in imposing monetary sanctions under Rule 9011 because that rule only authorizes sanctions upon attorneys, law firms or parties and does not extend to officers of a corporate party like Isaacson; however, the court had inherent power to punish contempt, and it did not err in exercising that power to impose monetary sanctions against Isaacson for her contumacious conduct; the bankruptcy judge did not err in denying Isaacson's recusal motion; the court adequately explained the basis for its decision to impose sanctions, and the amount of the sanctions satisfactorily reflected the seriousness of the behavior, the public interest and the importance of deterring such conduct.
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