Circuit split · civil procedure
Whether 28 U.S.C. § 1927's sanctions for unreasonably and vexatiously multiplying proceedings apply to pro se litigants
1 federal appellate case on this question, each acknowledging the disagreement in its own words.
- Alexander v. United States121 F3D 312
Seventh Circuit Court of Appeals · August 8, 1997
“Nonetheless, because there is a conflict among the circuits on the question whether § 1927 applies to pro se litigants, compare Wages v.” — Split of authority
Empirical analysis of this case →
The provision at issue
28 U.S.C. § 1927 — Counsels liability for excessive costs
“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.”Read the full section →
The other side of the split
Decisions the acknowledging court(s) named as the opposing or joined side, quoted in the acknowledging opinion's own words.
- On the other side · 9th Cir.Wages v. IRS915 F.2d 1230
“Nonetheless, because there is a conflict among the circuits on the question whether § 1927 applies to pro se litigants, compare Wages v.” — Alexander v. United States, acknowledging the split
- On the other side · 2d Cir.Sassower v. Field973 F.2d 75
“Field, 973 F.2d 75 , 80 (2d Cir.1992) (no), we look elsewhere for authority rather than choose sides unnecessarily.” — Alexander v. United States, acknowledging the split
What the split turns on
- Doctrines & tests:
- inherent powers
Cases are grouped by the legal question they announce a split on, classified from the court's own acknowledgment sentence. Verified acknowledgments only. Counter-side decisions are extracted from the acknowledging opinions' own text and linked only when the citation resolves in this corpus. See all circuit splits.