Sanctions Must Be Paid for Citing Unpublished Cases
Div. Three if the Fourth District Court of Appeal has decreed that a judge must determine, on remand, the amount of sanctions to be paid based on the appellant having impermissibly cited unpublished cases in its briefs on appeal and committing other violations of the rules of court and is also to decide whether the sums are to be paid by the party, its lawyer, or both.
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