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
citation_a.identifier: 774 N.W.2d 495, 495
citation_a.parenthetical: holding the district court abused its discretion by imposing-a sanction- that included fees expended before the sanctionable filings
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 also
citation_b.identifier: 989 F.2d 213, 218
citation_b.parenthetical: "[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."
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,