defendant, Governor Gretchen Whitmer (among others), “fraudulently and illegally manipulate[d] the vote count to make certain the election of Joe Biden as President of the United States.” The United States District Court for the Eastern District of Michigan held that the suit represented a “historic and profound abuse of the judicial process” and the claims were “intended to deceive” without regard to law or evidence. The Court determined that sanctions were warranted for advancing those claims, failing to conduct proper inquiry or investigation, and improperly delaying proceedings even after acknowledging that it was too late to attain the relief sought. 59 The Sixth Circuit Court of Appeals later overturned the sanctions for improper purpose, ruling that contesting election results is not an improper reason to bring suit, but it upheld the sanctions for false and misleading statements. 60 In a purported class action lawsuit on behalf of 160 million registered voters, lawyers representing a Virginia voter (among others) in the 2020 presidential election promoted claims of a “vast conspiracy” between state governors, secretaries of state, other election officials, Facebook, non-profit organizations, and Dominion Voting Systems to “interfere” with the election. The U.S. District Court for the District of Colorado, in O’Rourke v. Dominion Voting Systems, dismissed the suit for lack of standing and later enforced sanctions against the plaintiffs’ attorneys. The Tenth Circuit Court of Appeals upheld sanctions totaling USD $186,922.50, citing “intentional or reckless disregard of the attorney’s duties” where the attorney(s) “continu[ed] to pursue claims after a reasonable attorney would realize they lacked merit.” The Court of Appeals further stated that the attorneys “unreasonably and vexatiously multiplied the proceedings … without showing that the Plaintiffs had standing to bring their claims.” 61 At the July 2023 Electoral Integrity Project Summer Conference, when asked about the type of sanctions imposed for frivolous claims in the United States, one judge explained that: “Disciplinary actions against lawyers is a good thing … If you don’t have evidence, don’t bring it to the courts … Lawyers need to have facts behind them before bringing a lawsuit … We are not going to encourage the state to respond to frivolous case[s].” 62 Those words echoed throughout the rulings in the four cases mentioned above and strengthened the argument for sanctioning lawyers who have continued to advance attacks on the integrity of information in election cases. Sadly, lawyers and other officers of the court have also been central to many disinformation campaigns directed at the judiciary. This means outreach and coordination by judiciaries with bar councils and other ethics bodies will be increasingly needed. As noted by Jennifer Rubin, a lawyer and Washington Post columnist, in a webinar on disinformation for the National Center for State Courts (NCSC), actors attempt to weaken trust in the judiciary in many ways, often by spreading disinformation, and: King v. Whitmer, 556 F.Supp.3d 680 (2021). King v. Whitmer, No. 21-1786 (6th Cir. 2023). 61 O’Rourke v. Dominion Voting Sys., 552 F.Supp.3d 1168 (2021). 62 Tunheim, J. (2023, July 5). Court Litigation over Technology in Elections. In IFES (Chair), iEIP-2023 3rd Annual Virtual Electoral Integrity Conference [panel presentation]. 59 60 18