In Re: Alba Sanchez, 941 F.3d 625

In Sept. 2013, attorney Kenneth Rosellini filed a Chapter 7 petition for client Alba Sanchez in the E.D.N.Y. and then failed to prosecute the case.
The bankruptcy court issued multiple orders to show cause for Rosellini’s failures; he did not comply.
The bankruptcy court imposed a $1,000 monetary sanction against Rosellini, citing its inherent power to manage its docket and courtroom.
Rosellini moved to vacate and for reconsideration; the bankruptcy court denied relief.
The district court (Block, J.) affirmed; Rosellini appealed to the Second Circuit.
The Second Circuit (per curiam) addressed, as a matter of first impression in the Circuit, whether bankruptcy courts possess inherent sanctioning power and affirmed the $1,000 sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether bankruptcy courts possess inherent sanctioning power	Rosellini did not contest existence but challenged exercise; implicitly argued sanction improper	Bankruptcy court/district relied on precedent supporting inherent powers	Bankruptcy courts do possess inherent sanctioning powers, like Article III courts
Whether inherent power extends to non‑compensatory sanctions on attorneys	Rosellini argued the sanction was unwarranted here	Court: inherent power permits relatively minor non‑compensatory attorney sanctions to manage docket	Court affirmed that such minor sanctions are within bankruptcy courts’ inherent authority
Whether the bankruptcy court properly exercised its inherent power in this case (sanction amount $1,000)	Rosellini sought vacatur and reconsideration of the sanction	Bankruptcy court justified sanction for failure to prosecute and comply with show‑cause orders	Second Circuit affirmed the $1,000 sanction as appropriate
Standard of review and scope of appellate review	Rosellini sought reversal; argued lower courts erred on merits	Appellee/district court treated bankruptcy order under plenary review limited to the authority invoked	Court applied plenary review limited to the inherent‑power question and affirmed

Law v. Siegel, 571 U.S. 415 (recognizes that bankruptcy courts may possess inherent sanctioning authority)
Chambers v. NASCO, Inc., 501 U.S. 32 (establishes federal courts’ inherent powers to manage their affairs and sanction misconduct)
In re Kalikow, 602 F.3d 82 (2d Cir.) (discusses limits on sanction awards and the need to identify invoked authority)
Casse v. Key Bank Nat’l Ass’n (In re Casse), 198 F.3d 327 (2d Cir.) (notes bankruptcy courts can police dockets via inherent powers)
Charbono v. Sumski (In re Charbono), 790 F.3d 80 (1st Cir.) (collects appellate recognition that bankruptcy courts may impose inherent‑power sanctions)
United States v. Seltzer, 227 F.3d 36 (2d Cir.) (recognizes imposition of sanctions on attorneys)
Wilder v. GL Bus Lines, 258 F.3d 126 (2d Cir.) (per curiam) (acknowledges courts’ ability to impose non‑compensatory sanctions on attorneys)