King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) Rapids Mall Assoc., 98 F.3d at 929 (recognizing that an evidentiary hearing is “not necessarily required where the court has full knowledge of the facts and is familiar with the conduct of the attorneys”). Ultimately, when a court intends to invoke its inherent authority, “[a]t the very least, responsive briefing . . . [can] provide[] the procedural safeguards necessary.” KCI USA, Inc. v. Healthcare Essentials, Inc., 797 Fed.Appx. 1002, 1007 (6th Cir. 2020); see also Red Carpet Studios, 465 F.3d at 647 (finding that the court provided due process when sanctioning via its inherent authority where sanctioned party “argued his case in writing and at a hearing, and [] makes no argument why the notice and the hearing he received were inadequate”). Plaintiffs' lawyers have been afforded due process here. Through the multiple motions for sanctions and related briefs and during the July 12 motion hearing, they received notice of: (i) who sanctions were being sought against; (ii) the reasons why; (iii) the authority pursuant to which sanctions were requested; and (iv) the types of sanctions requested. Counsel were provided the opportunity to answer the sanctions allegations in responsive briefs, orally at the six-hour hearing, and in supplemental briefing. To the extent the Court questioned Plaintiffs' counsel about materials attached to their pleadings which had not been specifically addressed in the movants' briefs, counsel had an opportunity to respond to those concerns in their supplemental briefs-and counsel took advantage of that opportunity. (See, e.g., ECF No. 161 at Pg ID 5815-19; ECF No. 165 at Pg ID 6578-80; ECF No. 167 at Pg ID 6682-84, 6684 n.3). IV. Discussion 26 26 At last, this opinion arrives at the issue of whether Plaintiffs' attorneys should be sanctioned. The Court is aware of how long it took to get here. But addressing Plaintiffs' counsel's arguments concerning the Court's ability to impose sanctions was first required, and-as noted previouslythose arguments shifted and multiplied with each new brief they filed. A. Whether Plaintiffs' Counsel Violated 28 U.S.C. § 1927 The Court first considers whether Plaintiffs' counsel unreasonably and vexatiously multiplied proceedings by failing to dismiss this case when even they acknowledged it became moot. Ridder, 109 F.3d at 298 (quoting 28 U.S.C. § 1927). Plaintiffs expressly acknowledged in their petition for writ of certiorari to the Supreme Court that “[o]nce the electoral votes are cast, subsequent relief would be pointless, ” and “the petition would be moot.” (ECF No. 105 at Pg ID 4362 (citing ECF No. 105-2 at Pg ID 4401, 4409).) Michigan's electors cast their votes on December 14. “Yet, that date came and went with no acknowledgement by Plaintiffs and their counsel to Defendants or this Court, ” the State Defendants argue, forcing the State Defendants and Intervenor-Defendants to file motions to dismiss on December 22. (Id. (citing ECF No. 70); see also ECF Nos. 72, 73.) During the July 12 motion hearing, Campbell contended that-over the course of the litigation-“things change[d].” (ECF No. 157 at Pg ID 5345.) He explained, when this case was filed on November 25, counsel “thought honestly and truly that the drop-dead date was December 8th, and that's what [they] said to this Court.” (Id. at Pg ID 5346.) Later, “a judge in Wisconsin said, ” according to Campbell, “Well, why are you guys all hurrying for December 8th. It should be December 14th.” (Id.) Campbell continued, because “[s]omebody else came along and said, ‘Why not December 14th?' . . . [counsel] didn't argue with that” and gave the United States Supreme Court that date as the one upon which the case becomes moot. (Id.) And on December 14, “three [] [] Plaintiffs were, in their opinion, properly elected as electors” and, Campbell 20