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SANCTIONS
STANDARD OF REVIEW = ABUSE OF DISCRETION

A court's decision to deny sanctions under Rule 11, 28 U.S.C. § 1927, and the court's inherent power is reviewed for an abuse of discretion. See, e.g., Cordoba v. Dillard's, Inc., 419 F.3d 1169, 1179 (11th Cir. 2005); Baker v. Alderman, 158 F.3d 516, 521 (11th Cir. 1998). A district court abuses its discretion if it applies an incorrect legal standard, follows improper procedures in making the determination, or bases the decision "upon findings of fact that are clearly erroneous." Cordoba, 419 F.3d at 1180 (citation omitted).
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