Lawson v. Brown's Home Day Care Center, Inc.

¶ 1. Duncan Kilmartin appeals from the trial court’s order, on remand, upholding its imposition of $2000 in sanctions. The court found that Kilmartin acted in bad faith in filing unsealed materials from a confidential me diation session with the court. Kilmartin argues that the court’s order should be reversed because: (1) he was deprived of his due process right to advance notice that his conduct was proscribed; (2) due process required proof of his misconduct beyond a reasonable doubt; (3) the trial court erred in finding that he acted in bad faith; and (4) the court lacked jurisdiction to…