In Oliva v. NBTY, Inc., No. 13-14254 (11th Cir. Sept 22, 2014), appellant Glick represented plaintiffs in their personal injury lawsuit against defendants. The district court granted summary judgment in favor of defendants, and sanctioned Glick personally, under 28 U.S.C. § 1927, finding that he had caused defendants to incur more than $60,000 in “excess” attorney’s fees by filing motions that unreasonably and vexatiously multiplied the proceedings. Plaintiffs and defendants ultimately entered into a settlement, whereby defendants agreed to forego their fee petition against plaintiffs (but not Glick) in exchange for the right to receive a portion of plaintiffs’ eventual recovery in another lawsuit. On appeal, Glick argued that the parties’ settlement should bar defendants from attempting to collect the attorney’s fees sanction against him. The court disagreed, noting that the Glick was not a party to the settlement agreement. The court also rejected Glick’s argument that the settlement mooted the sanctions against him because defendants’ settlement recovery might fully cover (and exceed) the total amount of fees defendants actually incurred. The court held that the parties’ settlement of their attorney’s fees claims did not negate the district court’s authority under § 1927 to punish Glick personally for his conduct. The court reasoned that the purpose of § 1927 is to penalize attorneys whose conduct is so egregious that it is tantamount to bad faith, and that purpose is not negated if defendants might also collect their fees from a settlement with plaintiffs.