Attorney Fee Shifting: The Sanctioning Power of Section 1927 of Title 28, United States Code

This Comment examines the shifting of attorneys' fees under the courts' inherent power, Federal Rule of Procedure 11, and 28 United States Code, Section 1927. The Comment concludes that the power to sanction is non-uniform and weak. The Comment advocates a statutory interpretation of Section 1927 that supplies courts with the power to sanction attorneys for subjective as well as objective misconduct. Under this interpretation, the courts are given the comprehensive power to shift attorneys' fees.