The Fourth Circuit is showing signs of confirming a significant sanction of approximately $1 million against New York plaintiffs attorney Paul Napoli. The case revolves around allegedly frivolous court filings in a contentious dispute with another law firm over asbestos litigation client referrals. A judge on the panel has suggested that Napoli’s actions amount to a “collateral attack” on the authority of a federal court. For more details, see the original coverage by Law360.