context: P. 1.413(1) (emphasis added). This codifies a "but for" causation reqdirement, limiting a fee-based' sanction to the fees that would have been avoided but for the improper filings.
citation_a.signal: see also
citation_a.identifier: 914 F.2d 505, 523
citation_a.parenthetical: "Only attorney time which is in response to that which has been sanctioned should be evaluated."
citation_a.sentence: See Everly, 774 N.W.2d at 495. (holding the district court abused its discretion by imposing-a sanction- that included fees expended before the sanctionable filings); see also Bodenhamer Bldg. Corp. v. Architectural Research Corp.) 989 F.2d 213, 218 (6th Cir. 1993) (“[B]efore an award of attorneys’ fees may be made under [Rule 11], .it must be shown that the fees were- incurred be cause of the filing of an improper pleading.”); In re Kunstler, 914 F.2d 505, 523 (4th Cir. 1990) (“Only attorney time which is in response to that which has been sanctioned should be evaluated.”). As the United States Supreme Court recently explained,
citation_b.signal: see
citation_b.identifier: 774 N.W.2d 495, 495
citation_b.parenthetical: holding the district court abused its discretion by imposing-a sanction- that included fees expended before the sanctionable filings
citation_b.sentence: See Everly, 774 N.W.2d at 495. (holding the district court abused its discretion by imposing-a sanction- that included fees expended before the sanctionable filings); see also Bodenhamer Bldg. Corp. v. Architectural Research Corp.) 989 F.2d 213, 218 (6th Cir. 1993) (“[B]efore an award of attorneys’ fees may be made under [Rule 11], .it must be shown that the fees were- incurred be cause of the filing of an improper pleading.”); In re Kunstler, 914 F.2d 505, 523 (4th Cir. 1990) (“Only attorney time which is in response to that which has been sanctioned should be evaluated.”). As the United States Supreme Court recently explained,