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Rule 11 has not robbed the district courts of their inherent power to impose sanctions for abuse of the judicial system. In Chambers v. NASCO, Inc., 501 U.S. 32, 49, 115 L. Ed. 2d 27, 111 S. Ct. 2123 (1991), the Court was quite clear that 'the inherent power of a court can be invoked even if procedural rules exist which sanction the same conduct.' The Court stated that there was 'no basis for holding that the sanctioning scheme of the statute and the rules displaces the inherent power to impose sanction for . . . bad-faith conduct . . . .' 501 U.S. at 46. Even before Chambers courts recognized the inherent power of the district courts. See G. Heileman Brewing Co. v. Joseph Oat Corp., 871 F.2d 648 (7th Cir. 1989) (en banc). Courts have continued to make clear that there is a 'need to be cautious when resorting to inherent powers to justify an action, particularly when the matter is governed by other procedural rules . . . .' Kovilic Constr. Co. v. Missbrenner, 106 F.3d 768, 772-73 (7th Cir. 1997).
In order to sanction a party under ...
