The following excerpt is from Hawkins v. Kroger Co., Case No.: 15cv2320 JM(AHG) (S.D. Cal. 2020):
"When a court uses its inherent powers to impose sanctions that are criminal in nature, it must provide the same due process protections that would be available in a criminal contempt proceeding." F.J. Hanshaw, 244 F.3d at 1139. See also Miranda v. S. Pac. Transp. Co., 710 F.2d 516, 522 (9th Cir. 1983) (sanctions against attorneys should not be imposed without the procedural protections of notice, an opportunity to respond, and a hearing.)
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