Kaass Law v. Wells Fargo Bank, N.A.

In this appeal, Appellant Kaass Law challenges the district court’s' decision to grant Appellee Wells Fargo’s motion for sanctions against it pursuant to 28 U.S.C. § 1927 . We hold that 28 U.S.C. § 1927 does not permit the imposition of sanctions against a law firm, and we reverse the decision of the district court, and vacate its order imposing sanctions.

FACTUAL AND PROCEDURAL BACKGROUND

I. The Complaint and Motion to Dismiss

On September 27, 2012, Armen Kiramijyan, an attorney with Kaass Law, filed a complaint on behalf of Plaintiff Izabell Manukyan against 10 different defendants, including Wells Fargo Bank. The complaint made various allegations relating to certain adverse information the defendants had reported to credit agencies, who then reflected the adverse information on Plaintiffs credit report. On October 29, 2012, Wells Fargo moved to dismiss Plaintiffs complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). Instead of responding to Wells Fargo’s motion to dismiss, or any of the motions to dismiss filed by the other defendants, on October 30, 2012, Mr. Kiramijyan filed a motion to amend the initial complaint, and attached a proposed first amended…