Pollard

MEMORANDUM *

Appellant Micha Star Liberty (Liberty) appeals the district court’s Order entered *17 February 21, 2007, sua sponte imposing sanctions against Liberty for failing to conduct a sufficient investigation prior to asserting a civil rights claim on behalf of her client.

The district court violated Liberty’s due process rights by ordering sanctions without notice and a reasonable opportunity to respond. See Navellier v. Sletten, 262 F.3d 923, 943 (9th Cir.2001) (“When a court imposes sanctions sua sponte, the general rule is that it must first issue an order to show cause why sanctions should not be imposed to give the lawyer or party an opportunity to explain his or her conduct.”) (citation omitted). Additionally, the district court lacked authority to impose sanctions for pleadings filed in state court prior to removal. See Buster v. Greisen, 104 F.3d 1186 , 1190 n. 4 (9th Cir.1997) (explaining that a party may be sanctioned by the district court based on pleading filed in state court only if the party urges the allegations of those pleadings after removal). Finally, Liberty did not engage in sanctionable conduct by amending her client’s complaint to include a civil…