JERRY E. SMITH, Circuit Judge:
This appeal of attorney sanctions requires us to decide whether a district court may sanction an attorney for filings made in state court prior to removal. Because we conclude that district courts are not authorized to do so, we reverse that portion of the award that is based on pre-removal conduct. Because, however, the sanctioned attorney continued to maintain her case in federal court long after she realized it had no merit, we affirm...
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