NCBRC CASES IN REVIEW
warranted the imposition of sanctions under Bankruptcy Rule 9011(b)(2). The
attorney misstated the law regarding when the continuance of a foreclosure sale
violates the automatic stay, and he further misstated the definition of “cash collateral”
so as to make it appear not to apply to estate property subject to a tax lien.
Bankruptcy courts often need to act quickly, the Court of Appeals observed, and they
should be able to assume that counsel are being truthful. Even when misleading
filings fail to deceive a court, filings supported only by artifice serve to delay the
proceedings and impose costs on the other parties. Here, moreover, the misleading
assertions were not merely erroneous detours made in pursuit of otherwise wellgrounded filings. Rather, in each instance, the attorney marshaled