Papadakis

Appellant Bruce P. Zelis, an attorney litigant appearing pro se, abused the appellate process by prosecuting a frivolous appeal for the purpose of delay. After we dismissed the appeal and indicated we were considering the imposition of sanctions, appellant filed a federal bankruptcy petition and informed us that, as a result, he was invulnerable to monetary sanctions. We will hold that an attorney cannot prevent the imposition of sanctions by filing a federal bankruptcy petition.

I.

Facts and Procedural History

The relevant facts may be briefly summarized. Zelis was respondents’ former attorney; in 1974, he persuaded them to invest in a pistachio-growing limited partnership of which he was the general partner.

Disputes between the parties resulted in litigation in 1979; that litigation settled, immediately prior to trial, in 1986. Under the terms of the settlement, Zelis agreed to pay respondents $120,000, to resign as general partner, and to cooperate in the election of a new general partner. As part of the settlement, the parties released all their claims relating to the subject matter, and Zelis stipulated to a judgment against himself of $120,000, entry of which…