What is the standard of review for certifying a pleading, motion or similar paper?

Code of Civil Procedure section 128.7 (section 128.7) requires attorneys (or parties if they are unrepresented) to certify that every pleading, motion or other similar paper filed with the court has merit and is not being presented for an improper purpose. (Musaelian v. Adams (2009) 45 Cal.4th 512, 516; Martorana v. Marlin & Saltzman (2009) 175 Cal.App.4th 685; see 128.7, subd. (b)(1)-(4).) If, after notice and a reasonable opportunity to respond, the court determines the certification was improper under the circumstances, it may impose an appropriate sanction. ( 128.7, subd. (c).) Sanctions may include payment to the movant of attorney fees incurred as a consequence of the violation. ( 128.7, subd. (d).)

b. Standard of review.