Sixth Circuit -- Carol Metz v. Unizan Bank

Carol Metz v. Unizan Bank 

Attorney's refiling of claims earlier dismissed with prejudice is sufficient to justify sanctions.

Improper purpose is established by the fact that a reply brief was required.

District court need not make specific finding of bad faith to justify sanctions.

No error in sanctioning under inherent authority where Rule 11 also applies.

No DP violation in imposition without a hearing.