In re Nora, 778 F.3d 662

Sheila Spencer's Wisconsin foreclosure case was removed to federal court by her attorney Wendy Nora, who asserted Freddie Mac was the real party in interest after internet research; the district court remanded and awarded fees to PNC Bank.
Nora moved for reconsideration (denied as frivolous) and appealed the fee award on behalf of Spencer and herself; the Seventh Circuit concluded the appeal lacked any colorable federal-jurisdiction basis and was sanctionably frivolous.
The Seventh Circuit issued an order to show cause why Nora should not be sanctioned under Fed. R. App. P. 38 and disciplined under Rule 46(c) for conduct unbecoming a bar member.
Nora filed multiple additional submissions (rehearing petition, partial responses, citations, postponement request) and attended a 20-minute hearing; she continued to repeat rejected arguments and to level unsubstantiated accusations against judges and opposing counsel.
The court found Nora’s filings part of a pattern of frivolous litigation and antagonistic conduct in multiple cases, noted prior discipline and sanctions, and concluded Rule 38 and Rule 46(c) sanctions were warranted.
The court imposed a $2,500 sanction, suspended unless Nora files further frivolous or needlessly antagonistic submissions, and directed the clerk to forward the opinion to Wisconsin’s Office of Lawyer Regulation.

Issue	Nora's Argument	PNC / Court's Argument	Held
Whether removal, motion to reconsider, and appeal were frivolous	Removal and appeal were justified by newly discovered Freddie Mac involvement; asked for evidentiary hearing	No colorable basis for federal jurisdiction; filings repeated rejected arguments and sought delay	Frivolous; sanctions appropriate under Rule 38
Whether Nora could appeal in her own name against the fee award	Nora claimed effect of fee order required her indemnity and permitted her appeal	Fee award was against Spencer only; Nora showed no indemnity obligation	Nora lacked standing; appeal on her own behalf was frivolous
Whether filings were litigated for improper purposes (delay/costs)	Denied improper motive; sought hearings/evidentiary proof	Pattern and timing suggest strategy to delay foreclosure and increase costs	Court concluded filings motivated by improper delay and sanctioned
Whether Nora's accusatory filings warranted discipline under Rule 46(c)	Characterized criticisms as rude but not sanctionable; sought evidentiary hearing	Repeated, serious accusations without factual or legal basis; pattern of antagonistic conduct	Conduct unbecoming; sanctions warranted and discipline referral made

PNC Bank, N.A. v. Spencer, 763 F.3d 650 (7th Cir. 2014) (previous opinion finding appeal frivolous)
In re Nora, 450 N.W.2d 328 (Minn. 1990) (prior suspension for similar litigation tactics)
In re Ruffalo, 390 U.S. 544 (1968) (due-process notice and opportunity to respond before discipline)
Lightspeed Media Corp. v. Smith, 761 F.3d 699 (7th Cir. 2014) (discussing Ruffalo standards)
Wachovia Sec., LLC v. Loop Corp., 726 F.3d 899 (7th Cir. 2013) (Rule 38 sanctions standard)
Hartz v. Friedman, 919 F.2d 469 (7th Cir. 1990) (sanctions for frivolous appeals)
Mays v. Chi. Sun-Times, 865 F.2d 134 (7th Cir. 1989) (sanctioning frivolous litigation tactics)
In re Lightfoot, 217 F.3d 914 (7th Cir. 2000) (Rule 46(c) standards)
In re Hendrix, 986 F.2d 195 (7th Cir. 1993) (sanctions for filings not grounded in law or fact)
Liteky v. United States, 510 U.S. 540 (1994) (judicial rulings alone rarely show disqualifying bias)