Musnuff v. Haeger

(1) Whether a federal court may impose sanctions against an attorney for non-disclosure of documents without either affording heightened procedural protections, as required for punitive sanctions, or finding a causal relationship between the sanctioned conduct and the amount awarded, as required for compensatory sanctions; and (2) Is a federal court required to tailor compensatory civil sanctions imposed under inherent powers to harm directly caused by sanctionable misconduct when the court does not afford sanctioned parties the protections of criminal due process?