D. Colorado Notes Split Re Whether Sec. 1927 Authorizes Fee Awards agaisnt Law Firms

Per Medtronic Navigation, Inc. v. BrainLAB Medizinische Computersystems Gmbh,
Slip Copy, 2008 WL 410413 (D. Colo. Feb. 12, 2008):

There is a split of authority on the question of whether section 1927 authorizes fee awards against law firms. See Claiborne v. Wisdom, 414 F.3d 715, 722-24 (7th Cir.2005) (discussing circuit split and concluding that “ § 1927 does not provide a legal basis for an order of fees against an entity like a law firm that is not itself ‘admitted to practice’ ”). The United States Court of Appeals for the Tenth Circuit has not addressed this issue.