Langrock Sperry v. Citigroup, 702 F.3d 720

Langrock represented Wilson and moved to dismiss related claims by Citigroup defendants.
Langrock sought extensions to file opposition; the parties signed a stipulation extending to July 28, 2011, but ECF rejection led to issues.
Reed faxed a due-date extension letter citing substantial scheduling conflicts and other obligations.
Langrock filed untimely opposition on July 15, 2011; the district court later granted leave to file late for good cause.
District court ordered Langrock to pay Citigroup's fees (totaling $24,398.83) as a sanction for the late filing; Langrock paid the amount.
Langrock timely appealed the sanctions order; the Second Circuit held the sanctions were abusive and reversed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sanctions require a finding of bad faith.	Langrock argues no explicit bad-faith finding.	Citigroup argues sanctions do not require bad-faith finding.	Yes, explicit bad-faith finding required; sanctions reversed.
Whether due process protections (notice and opportunity to be heard) were satisfied before sanctions.	Langrock contends there was no notice or hearing.	Citigroup argues sanctions followed court discretion.	No due process; sanctions reversed.

Seltzer v. United States, 227 F.3d 36 (2d Cir. 2000) (explicit bad-faith finding required for attorney-fee sanctions under inherent power)
Sakon v. Andreo, 119 F.3d 109 (2d Cir. 1997) (due process protections before sanctions must be provided)
Roadway Express, Inc. v. Piper, 447 U.S. 752 (U.S. 1980) (strict limitations on fee sanctions for abusive litigation practices)
Oliveri v. Thompson, 803 F.2d 1265 (2d Cir. 1986) (stringent standards for when sanctions are appropriate and require clear evidence of improper purpose)
Dow Chemical Co. v. Rascator Maritime S.A., 782 F.2d 344 (2d Cir. 1986) (requires strong factual findings for sanctions in international procurement context)