Positive Software Solutions, Inc. v. New Century Mortgage Corp.

JERRY E. SMITH, Circuit Judge:

Ophelia Camina appeals the district court’s imposition of sanctions for her conduct during arbitration. Because that court lacked inherent authority to impose those sanctions, we reverse and remand.

I

In 2003, Positive Software Solutions, Inc. (“Positive Software”), sued New Century Mortgage Corporation (“New Century”) for allegedly infringing telemarketing software licensed to New Century. Ophelia Camina, a partner at Susman Godfrey LLP, appeared as attorney for New Century. Over Positive Software’s objection, the district court ordered the case to arbitration in…