Ruben Santoyo v. City of Chicago, Illinois, et al.
DueProcess
Whether a district court may impose punitive monetary sanctions sua sponte after a notice of appeal has divested it of jurisdiction, in light of conflicting circuit authority
1. Jurisdiction after appeal. Whether a district court may impose a punitive monetary sanction sua sponte after a notice of appeal has divested it of jurisdiction under Griggs v. Provident Consumer Discount Co., 459 U.S. 56 (1982), in light of conflicting circuit authority on whether such sanctions are "collateral" or "ministerial." (Compare Overnite Transp. Co. v. Chicago Indus. Tire Co., 697 F.2d 789 (7th Cir. 1983) (barring such sanctions), with Schlaifer Nance & Co. v. Estate of Warhol, 194 F.3d 323 (2d Cir. 1999); In re Ruben, 825 F.2d 977 (6th Cir. 1987); and Hicks v. S. Md. Health Sys. Agency, 805 F.2d 1165 (4th Cir. 1986) (permitting post-appeal sanctions)). 2. Due process for sanctions. Whether the Due Process Clause permits a court to impose a substantial monetary sanction based solely on generalized warnings, without motion, specific notice, or a hearing —where other circuits require explicit notice and a meaningful opportunity to be heard. (See Sanko Steamship Co. v. Galin, 835 F.2d 51 (2d Cir. 1987); CEATS, Inc. v. TicketNetwork, Inc., No. 21-40705 (5th Cir. June 19, 2023); United States v. Tillman, No. 13-10131 (9th Cir. June 30, 2014)). 3. Access to justice & Artificial Intelligence. Whether sanctioning a pro se litigant for the disclosed, good-faith use of Al-assisted drafting tools infringes upon the First Amendment right to petition and the fundamental right of access to courts, by chilling modem means of meaningful participation in the judicial process (contrary to the protections established in Bounds v. Smith, 430 U.S. 817 (1977), and Haines v. Kerner, 404 U.S. 519 (1972)).