Brock v. Logsdon  ·  2022-07-26  ·  W.D. New York  ·  pin 146 F.3d at 126

“appellate courts have ruled that, in certain sanctions proceedings, the person facing imposition of sanctions should have the benefit of the procedural protections available to a person charged with a crime.”

Mackler Productions, Inc. v. Frank R. Cohen  ·  2000-08-29  ·  Second Circuit  ·  pin 146 F.3d at 126

"Mackler II"