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Over the past decade, federal courts have come to rely primarily on sanctions to control the conduct of attorneys.' Often, courts hold lawyers and their clients jointly and severally liable for conduct such as discovery abuse, unwarranted factual contentions, vexatious multiplication of the proceedings, or civil contempt.2 When courts impose monetary sanctions, they usually make the sanctions payable to the opposing party.3 If sanctions are payable to an opponent, rather than the court, a client can settle the case and all related sanctions. Although the client may appraise the sanction at approximately its face value, the lawyer, a repeat player in the judicial system, usually attaches far greater significance to the sanction.4 Even when a client fails to seek contribution for payment of a

The Settled Sanction: Post-Settlement Appeal and Vacatur of Attorney Sanctions Payable to an Opponent