Williams v. Blueprint, LLC, 952 F. Supp. 2d 209

Williams obtained a default judgment against BluePRINT, LLC for $142,961.00 on June 10, 2011.
Williams sought to discover BluePRINT’s assets through interrogatories and motions to compel responses.
BluePRINT repeatedly failed to provide complete, accurate, sworn responses; contempt and show-cause proceedings ensued.
BluePRINT’s owner, Rudolph Cline-Thomas, was found in contempt multiple times and jailed during proceedings until full responses were provided.
BluePRINT ultimately satisfied the judgment by a check, and the matter proceeded to Williams’ request for postjudgment attorney fees, costs, and interest.
The court ultimately denied Williams’ motion for fees under 28 U.S.C. § 1927 and denied postjudgment interest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1927 allows fees against BluePRINT and its owner.	Williams argues § 1927 authorizes fees for vexatious conduct by BluePRINT and its counsel.	BluePRINT contends § 1927 applies to attorneys, not non-lawyers like BluePRINT or Cline-Thomas.	§ 1927 does not apply to BluePRINT or Cline-Thomas; fees denied.
Whether sanctions for vexatious conduct were warranted under § 1927.	Williams asserts conduct justified sanctions and fee shifting.	BluePRINT argues there was no sanctionable attorney conduct; primarily client behavior.	Vexatious sanctions under § 1927 not warranted; statute inapplicable to non-attorneys.
Whether postjudgment interest of $498.38 should be awarded.	Williams seeks postjudgment interest from judgment date to satisfaction.	BluePRINT’s conduct caused delay; interest should be awarded as part of the judgment.	Postjudgment interest denied; cost-saving rationale and judicial economy favored denial.

Oliveri v. Thompson, 803 F.2d 1265 (2d Cir. 1986) (§ 1927 targets attorney conduct, not clients)
In re Crescent City Estates, LLC, 588 F.3d 822 (4th Cir. 2009) (high standard for sanctions against attorneys remains)