Patricia Meadow v. Goodrich Corporation, 20-16753

Patricia Meadow was injured while working for a contractor at a Goodrich facility and sued Goodrich under Arizona negligence and premises-liability law.
The district court granted summary judgment for Goodrich, concluding Goodrich was statutorily immune from Meadow’s claims under Arizona law.
Goodrich moved for attorney-sanctions under 28 U.S.C. § 1927, arguing Meadow’s counsel unreasonably and vexatiously pursued claims despite obvious statutory immunity.
The district court denied § 1927 sanctions, finding no evidence of subjective bad faith and that the merits required a fact-specific inquiry.
On appeal, the Ninth Circuit reviewed the denial of § 1927 sanctions for abuse of discretion and affirmed the district court’s decision.
The panel declined to address Meadow’s late challenge to the underlying summary-judgment order because she failed to file a timely notice of cross-appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying § 1927 sanctions	Meadow’s counsel pursued a fact-specific, non-frivolous claim; no bad faith	Counsel unreasonably multiplied proceedings despite apparent statutory immunity	Affirmed — no abuse; district court reasonably found no subjective bad faith
Standard for imposing § 1927 sanctions (subjective bad faith)	Counsel did not act knowingly or recklessly; no intent to harass	§ 1927 requires sanctions for unreasonable, vexatious multiplication of proceedings and bad faith	Court reiterates § 1927 requires subjective bad faith; record did not show it here
Whether the court could consider Meadow’s challenge to summary judgment on appeal without a cross-appeal	Meadow raised merits in her answering brief	Goodrich argued challenge was untimely and required a notice of cross-appeal	Court declined to address the untimely challenge because Meadow did not file a timely cross-appeal

Kaass L. v. Wells Fargo Bank, N.A., 799 F.3d 1290 (9th Cir. 2015) (standard of review for sanctions motions)
United States v. Hinkson, 585 F.3d 1247 (9th Cir. 2009) (abuse-of-discretion framework explained)
Blixseth v. Yellowstone Mountain Club, LLC, 796 F.3d 1004 (9th Cir. 2015) (§ 1927 requires a finding of subjective bad faith)
B.K.B. v. Maui Police Dep’t, 276 F.3d 1091 (9th Cir. 2002) (subjective bad faith shown by knowingly or recklessly raising frivolous claims)
Trulis v. Barton, 107 F.3d 685 (9th Cir. 1995) (district courts have broad discretion in imposing § 1927 sanctions)
Lee v. Burlington N. Santa Fe Ry. Co., 245 F.3d 1102 (9th Cir. 2001) (need for a notice of cross-appeal to raise certain issues on appeal)