28 U.S.C. § 1927
Section 1927 · Counsels liability for excessive costs
Amended 2 times on record
The circuits are split over this section — Whether 28 U.S.C. § 1927's sanctions for unreasonably and vexatiously multiplying proceedings apply to pro se litigants
Applied in 3,366 court decisions — leading case Cooter & Gell v. Hartmarx Corp. (1990)
Most recently applied in Rowland v. Watch Tower Bible and Tract Society of New York, Inc. (July 2025)
Applied most in the Ninth Circuit Circuit (201 decisions)
Cases citing this section usually also cite 42 U.S.C. § 1988 · 42 U.S.C. § 1983 · 28 U.S.C. § 1291
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Any attorney or other person admitted to conduct cases in any court of the United States or any Territory thereof who so multiplies the proceedings in any case unreasonably and vexatiously may be required by the court to satisfy personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 28, U.S.C., 1940 ed., §829 (R.S. §982).
Word “personally” was inserted upon authority of Motion Picture Patents Co. v. Steiner et al., 1912, 201 F. 63, 119 C.C.A. 401. Reference to “proctor” was omitted as covered by the revised section.
See definition of “court of the United States” in section 451 of this title.
Changes were made in phraseology.
Amendments
1980—Pub. L. 96–349 substituted judicial authorization to require attorneys to satisfy excess costs, expenses, and attorneys’ fees reasonably incurred because of multiplication of proceedings for such prior authority to impose liability for increased costs based on multiplication of proceedings.
Federal Rules of Civil Procedure
Costs, see rules 11 and 54, Appendix to this title.