Kendricka Sandifer v. Orleans Parish Government, e, 637 F. App'x 117

Kendrica Sandifer sued members of the Orleans Parish Sheriff’s Office alleging sexual harassment and related claims (Sandifer I); Jerry Settle was her counsel. Trial was scheduled and then continued.
Sandifer sought to add John Courtney Wilson as co-counsel; the district court twice denied enrollment, citing a calendar conflict and prior concerns about Wilson’s competence.
After administrative exhaustion issues, Sandifer (with Wilson and Settle listed) filed a new related suit (Sandifer II); the court struck Wilson from the record for attempting an "end run" around the earlier denial and ordered him to show cause.
Settle later filed a third related complaint (Sandifer III). Wilson was involved in drafting/filing aspects of that complaint (initially filed signed only by Settle), then moved to enroll as co-counsel; the magistrate approved enrollment and the case was consolidated with the earlier matters.
The district court found Wilson violated prior court orders and his duty of candor, prohibited him from drafting documents or acting as a de facto attorney for Sandifer, and imposed a $1,000 monetary sanction. Wilson appealed; the Fifth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wilson should have been allowed to enroll as co-counsel in Sandifer I	Sandifer: sought to enroll Wilson to assist counsel	Court/Defendants: enrollment improper because Wilson disclosed a scheduling conflict and the court doubted his competence	Denial affirmed (issue inadequately briefed on appeal and moot after final judgment)
Whether Wilson should have been struck as counsel in Sandifer II	Sandifer: Wilson listed as counsel on new filing	Court/Defendants: Wilson attempted to circumvent prior denial by refiling; striking was appropriate	Striking affirmed (issue waived on appeal)
Whether the $1,000 sanction and restrictions in Sandifer III were improper	Wilson: sanctions unjustified; lack of authorization/notice argued on appeal	Court/Defendants: Wilson knowingly violated prior orders, obscured involvement, and acted in bad faith	Sanction and prohibitions affirmed — district court did not abuse its discretion

Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (courts possess inherent authority to sanction for bad-faith conduct and disobedience of orders)
Link v. Wabash R. Co., 370 U.S. 626 (1962) (courts’ power to manage proceedings to secure orderly disposition)
Anderson v. City of Bessemer City, 470 U.S. 564 (1985) (appellate review: factual findings not overturned unless clearly erroneous)
In re First City Bancorporation of Texas, Inc., 282 F.3d 864 (5th Cir. 2002) (sanctioning court must use least restrictive sanction that will deter misconduct)
Crowe v. Smith, 261 F.3d 558 (5th Cir. 2001) (appellate standard for abuse of discretion in bad-faith findings)
Elliott v. Tilton, 64 F.3d 213 (5th Cir. 1995) (review standard for sanctions imposed under court’s inherent authority)