Courts may not impose punitive sanctions upon attorneys to deter colorable arguments that insulate judicial determinations from legitimate challenges without implicating central First Amendment concerns and/or violating the Eighth Amendment prohibition against excessive fines. In this purported civil rights case, Respondents, a private hospital system, attempted to conceal their health care fraud scheme and the lack of federal subject matter jurisdiction by ignoring federal disclosure requirements and through material misrepresentations made to the district court regarding their employment relationship with Plaintiff. Thus, the true catalyst for Respondents' retaliation through punitive sanctions is Petitioner's discovery of the sophisticated healthcare scheme that exposed Plaintiff's employment by a private actor and lack of state action required to bring a claim pursuant to 42 U.S.C. § 1983. Moreover, while this case was pending on appeal for the first time, an intervening and controlling decision was released by the Louisiana Supreme Court and Respondents were judicially determined to be private employers in a vaccine mandate case thereby implicating principles of estoppel and the subject matter jurisdiction of the federal courts.

1. Whether the lower courts imposition of punitive sanctions violates Petitioner's rights under the First and/or Eighth Amendments to the United States Constitution where Petitioner made arguments supported by existing law/evidence and complied with her duties as an officer of the court.

2. Whether the lower courts abused its constitutional authority by failing to examine its jurisdiction, uncontroverted evidence in the record, and/or give full faith and credit to an intervening and controlling decision of the Louisiana Supreme Court.

Whether the lower courts' imposition of punitive sanctions violates Petitioner's rights under the First and/or Eighth Amendments