No. 25-7373October Term 2025Petition Pending
Scott Erik Stafne, Petitioner v. Quality Loan Service Corporation of Washington, et al.
Scott Erik Stafne asks the Supreme Court to review Rule 11 sanctions imposed on him for raising a structural constitutional challenge to a judicial officer’s authority to exercise Article III power.
Case status
- Current stage
- Petition Pending
- Latest event
- Petition pending
- Decision timing
- No decision timeline until the Court agrees to hear the case.
- What it's about
Scott Erik Stafne asks the Supreme Court to review Rule 11 sanctions imposed on him for raising a structural constitutional challenge to a judicial officer’s authority to exercise Article III power. He argues that a lawyer should not be sanctioned for making a nonfrivolous constitutional argument that the Supreme Court and the governing court of appeals have not definitively resolved.
Question presented
1. Whether Federal Rule of Civil Procedure 11 permits a federal court to impose sanctions upon an attorney for presenting a nonfrivolous structural constitutional challenge concerning the authority of a judicial officer to exercise Article III judicial power, where the challenge is grounded in constitutional text, statutory interpretation, and historical evidence, and where that constitutional question has not been definitively resolved by this Court or the court of appeals governing the district court. 2. Whether, under this Court’s decisions in Griggs v. Provident Consumer Discount Co., 459 U.S. 56 (1982), and Coinbase, Inc. v. Bielski, 599 U.S. 736 (2023), a district court retains jurisdiction to impose Rule 11 sanctions based on arguments concerning its authority to proceed after a notice of appeal invoking the collateral order doctrine has transferred jurisdiction over those issues to the court of appeals?
- Case path
United States Court of Appeals for the Ninth Circuit / Petition pending
- Area
Petition for review pending
Briefing
What it's about
Scott Erik Stafne asks the Supreme Court to review Rule 11 sanctions imposed after he challenged a judicial officer's authority to exercise Article III judicial power. He also argues that the district court lacked authority to impose sanctions after his appeal transferred the issue to the Ninth Circuit.
Argument
The case is pending, and oral argument has not been scheduled. Stafne argues that Rule 11 should not punish a nonfrivolous constitutional challenge and that his appeal limited the district court's authority to act.
Impact
The case could affect lawyers who raise unresolved constitutional arguments in federal court. For example, an attorney challenging a court officer's authority could face sanctions even if the argument has not been definitively resolved.
What is at stake in Stafne v. Quality Loan Service?
The case concerns whether a lawyer may be sanctioned for an unresolved constitutional challenge to a judicial officer's authority.
Who could be affected by the Stafne case?
Lawyers and federal courts could be affected when attorneys make nonfrivolous constitutional arguments that governing courts have not definitively resolved.
What happens next in Stafne v. Quality Loan Service?
The Supreme Court may decide whether to grant certiorari and hear the case. Oral argument has not been scheduled.
Related cases
Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Sep 3, 2026
- Method
- Methodology