6. Courts have statutory authority under 28 U.S.C. § 1927 to impose excess costs on an attorney “who so multiplies the proceedings in any case unreasonably and vexatiously.” It is an open question whether the imposition of sanctions requires a showing of subjective bad faith or objective unreasonableness. See Cochran,The Reality of “A Last Victim” and Abuse of the Sanctioning Power, 37 Loy. L.A. L. Rev. 691 (2004). Courts also have inherent power to sanction parties, and this power is neither constrained nor supplanted by Rule 11 or 28 U.S.C. § 1927.