Virginia Properties, LLC v. T-Mobile Northeast LLC

VILARDO, District Judge:

In April of this year—long after the district court’s imposition of sanctions in the case before us—the Supreme Court addressed “a federal court’s inherent authority to sanction a litigant for bad-faith conduct by ordering it to pay the other side’s legal fees.” Goodyear Tire & Rubber Co. v. Haeger, — U.S. —, 137 S.Ct. 1178, 1183-84, 197 L.Ed.2d 585 (2017). The Court held “that such an order is limited to the fees the innocent party incurred solely because of the misconduct—or put another way, to the fees that party would not have incurred but for the bad faith.” Id.…