Williams v. Biomedical Research, 22-30064

Plaintiff's counsel Victoria Plante-Northington emailed the district court's career law clerk (Sept. 8) expressing frustration about a year-long pending motion and asking whether to file a joint pretrial order; message included a smiley face and a comment that the magistrate advised "it was better not to ask the court to rule."
At a Sept. 21, 2021 pretrial conference the district judge read the email into the record, characterized it as "impertinent," "smartass and unprofessional," and found counsel acted in "bad faith."
The district court immediately imposed sanctions under its inherent power: five additional CLE professionalism hours (with reporting requirements) and notification to state bars; the court cut off Plante-Northington when she tried to respond.
The parties later settled the underlying employment claims; Plante-Northington appealed the sanctions order arguing (1) lack of due process and (2) that her conduct was not sanctionable.
The Fifth Circuit reviewed for abuse of discretion and focused on procedural safeguards required before imposing inherent-power sanctions.
The Fifth Circuit vacated the sanctions and remanded for further proceedings because the district court did not provide adequate notice or a meaningful opportunity to respond; the appellate court declined to resolve the merits of sanctionability on the existing record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether imposition of sanctions complied with due process (notice and opportunity to respond)	Plante‑Northington: no adequate advance notice or meaningful opportunity to prepare a response; on‑the‑spot treatment violated due process	District court: acted within inherent power and could impose sanction at oral hearing based on conduct shown by the email	Vacated. Court held district court abused discretion by imposing sanctions without specific notice and a fair opportunity to respond; remanded for proceedings compliant with due process
Whether Plante‑Northington's email was sanctionable (bad faith/abusive conduct)	Plante‑Northington: email was not disrespectful or in bad faith; no sanctionable misconduct	District court: email criticized docket management and constituted abusive conduct warranting inherent‑power sanction	Not decided on appeal. Court remanded so district court may reconsider the sanctionability question after affording proper process

Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (courts have inherent powers but must exercise them with caution and respect due process)
Roadway Exp., Inc. v. Piper, 447 U.S. 752 (1980) (sanctions should not be assessed without fair notice and an opportunity for a hearing on the record)
1488, Inc. v. Philsec Inv. Corp., 939 F.2d 1281 (5th Cir.) (advance notice may sometimes be excused by clear codified rules; otherwise notice and response required)
Spiller v. Ella Smithers Geriatric Ctr., 919 F.2d 339 (5th Cir.) (specific notice of reasons for contemplating sanctions and an opportunity to respond are required)
Thornton v. Gen. Motors Corp., 136 F.3d 450 (5th Cir.) (failure to afford due process when imposing sanctions is an abuse of discretion)
Matter of Dallas Roadster, Ltd., 846 F.3d 112 (5th Cir.) (remand appropriate where sanctions were imposed without adequate procedural safeguards)