The following excerpt is from Snell, In re, 103 F.3d 140 (9th Cir. 1996):
We review de novo whether a sanctioned party violated Rule 11, or in this case, the equivalent Bankruptcy Code Rule 9011. Warren v. Guelker, 29 F.3d 1386, 1388 (9th Cir.1994). Here, the district court was correct in reversing the bankruptcy court's imposition of sanctions. Bernard's conduct as a pro se party in the bankruptcy court did not justify such an award. See id., at 1390 ("Although Rule 11 applies to pro se plaintiffs, the court must take into account a plaintiff's pro se status when it determines whether the filing was reasonable.").
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