King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) 9. Plaintiffs “intentional[ly] lie[d]” by filing the “analysis” of William M. Briggs, who relied on “survey” results posted in a tweet by Matt Braynard and the “survey” “misrepresents Michigan election laws”; “disregards standard analytical procedures”; contains “a baffling array of inconsistent numbers”; and includes “conclusions [that are] without merit” (id. at Pg ID 3654-58). The City maintains that monetary sanctions sufficient to deter future misconduct by counsel must include the amount counsel collected in their fundraising campaign to challenge the 2020 election, as well as the attorneys' fees Defendants incurred to defend against Plaintiffs' claims. (Id. at Pg ID 3662-63.) The City also seeks an injunction barring Plaintiffs and their counsel from filing future actions in this District without obtaining approval from a judicial officer and asks the Court to refer counsel for discipline and disbarment.9 (Id. at Pg ID 3664, 3666-69.) 9 The City also argues that “this is the rare case where the Plaintiffs themselves deserve severe sanctions.” (ECF No. 78 at Pg ID 3664.) “Rule 11 expressly provides the district court with discretion to impose sanctions on a party that is responsible for the rule's violation, provided that the violation is not one for unwarranted legal contentions under Rule 11(b)(2).” Rentz v. Dynasty Apparel Indus., Inc., 556 F.3d 389, 398 (6th Cir. 2009) (citing Fed.R.Civ.P. 11(c)(1), (c)(5)(A)). Nevertheless, courts generally decline to do so, and the Sixth Circuit has reserved such sanctions for occasions where the party can be said to have caused the violation. Id. The Court is unable to reach that conclusion here, particularly given that it is Plaintiffs' counsel, not Plaintiffs, who have filed similar legally frivolous lawsuits in other battleground states. C. Davis Davis seeks sanctions against Plaintiffs and their counsel pursuant to the Court's inherent authority and § 1927, based on many of the same legal and factual deficiencies set forth by the State Defendants, the City, and this Court in its December 7 decision. (ECF No. 69.) III. Applicable Law A. Sanctions Pursuant to 28 U.S.C. § 1927 “Section 1927 provides that any attorney ‘who so multiplies the proceedings in any case unreasonably and vexatiously may be required by the court to satisfy personally the excess of costs, expenses, and attorneys' fees reasonably incurred because of such conduct.'” Ridder v. City of Springfield, 109 F.3d 288, 298 (6th Cir. 1997) (quoting 28 U.S.C. § 1927). The purpose of a sanctions award under this provision is to “deter dilatory litigation practices and to punish aggressive tactics that far exceed zealous advocacy.” Red Carpet Studios Div. of Source Advantage, Ltd. v. Sater, 465 F.3d 642, 646 (6th Cir. 2006). Section 1927 imposes an objective standard of conduct on attorneys, and courts need not make a finding of subjective bad faith before assessing monetary sanctions. Id. (citing Jones v. Cont'l Corp., 789 F.2d 1225, 1230 (6th Cir. 1986)). A court need only determine that “an attorney reasonably should know that a claim pursued is frivolous.” Id. (quoting Jones, 789 F.2d at 1230). “Simple inadvertence or negligence, however, will not support sanctions under § 1927.” Salkil v. Mount Sterling Twp. Police Dep't, 458 F.3d 520, 532 (6th Cir. 2006) (citing Ridder, 109 F.3d at 298); see also Red Carpet Studios, 465 F.3d at 646 (holding that “§ 1927 sanctions require a showing of something less than subjective bad faith, but something more than negligence or incompetence”). Ultimately, “[t]here must be some conduct on the part of the subject attorney that trial judges, applying collective wisdom of their experience on the bench, could agree falls short of the obligations owed by a member of the 8