Sanctions of $10,000 for failure to disclose party-defendant's death affirmed

In Glucksberg v. Polan, the Fourth Circuit in a per curiam opinion for the panel of Judges Widener and Michael and Senior Judge Hamilton affirmed the sanction of $10,000 imposed against one of the litigants by District Judge Goodwin, based on these circumstances:

"The sanction resulted from Polan’s failure to properly notify the court, during a proceeding in which he and his father were the defendants, that his father had died and that he was not a co-executor of his father’s estate, as the plaintiffs believed. As a result of these failures, a judgment previously entered in favor of the plaintiffs in the amount of $208,637.50 had to be vacated."