What is the test for imposing sanctions on a local rule violation?

It also provides, however, that "No penalty may be imposed under this section without prior notice to, and an opportunity to be heard by, the party against whom the penalty is sought to be imposed." (Code Civ. Proc., 575.2, subd. (a).) Failure to give the required notice before imposing sanctions for local rule violations exceeds a trial court's authority, and renders a resulting judgment voidable. (See Lee v. An (2008) 168 Cal.App.4th 558, 565-566.)