What is the current state of the law on the power of a court to sanction counsel or litigant for bad faith conduct?

A court has the inherent power to supervise and control its own proceedings and to sanction counsel or a litigant for bad-faith conduct. See, e.g., Chambers v. NASCO, 501 U.S. at 43-50, 111 S.Ct. at 2132-36. While Rule 11 extends only to papers filed with the court, the court's inherent power is broader and would permit the court to impose sanctions on the basis of related bad-faith conduct prior to the commencement of the litigation, see Chambers v. NASCO, 501 U.S. at 36, 40-41, 44, 111 S.Ct. at 2128, 2130-31, 2132-33. Though the imposition of sanctions

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