Whether an attorney whose name is designated as 'Of Counsel' on the signature page of a frivolous pleading that the attorney did not sign, file, submit or later advocate, may nonetheless be held responsible for Rule 11 sanctions

QUESTIONS PRESENTED Petitioner, L. Lin Wood, was an attorney licensed to practice in federal and state courts in the State of Georgia. On November 25, 2020, plaintiffs filed a lawsuit in the Eastern District of Michigan against the Michigan Governor, the Michigan Secretary of State and the Michigan Board of State Canvassers, seeking injunctive relief concerning the results of the 2020 presidential election. The complaint was voluntarily dismissed on January 14, 2021. Mr. Wood’s name appeared on the signature page of the complaint, under the heading “Of Counsel.” On January 5, 2021, the City of Detroit sought sanctions against Mr. Wood pursuant to Fed. R. Civ. P. 11. The state defendants did not seek sanctions against Mr. Wood. Detroit sent a letter to Mr. Wood on December 15, 2020, enclosing a short motion for Rule 11 sanctions. The district court concluded the rule’s 21-day safe harbor period began running that day. The motion, however, differed significantly from the motion for sanctions it ultimately filed and litigated in its allegations and request for sanctions. The Sixth Circuit upheld most of the district court sanctions order. The questions presented are: 1. Whether an attorney whose name is designated as “Of Counsel’ on the signature page of a frivolous pleading that the attorney did not sign, file, submit or later advocate, may nonetheless be held responsible for Rule 11 sanctions. 2. Whether the serving of a short sanctions motion, that seeks relief significantly different from that ultimately sought in a subsequently filed motion ii and brief, nonetheless initiates the 21-day safe-harbor period pursuant to Rule 11(c)(2).