the extent to which notice and an opportunity for hearing are required under Civil Rule 95(a). However, we are requesting our Standing Advisory Committee on Civil Rules to consider this question. 47 . Roadway Express, Inc. v. Piper, 447 U.S. 752, 767, 100 S.Ct. 2455, 65 L.Ed.2d 488 (1980) (concluding that federal courts possess "inherent power” to-assess contempt sanctions). After the Supreme Court decided Roadway, Congress amended 28 U.S.C. § 1927 to provide that a court may assess attorney’s fees against an attorney. 28 U.S.C. § 1927 (2000); see Morris v. Adams-Millis Corp., 758 F.2d 1352, 1357 n. 7 (10th Cir.1985). 48 . Id. at 767 n. 14, 100 S.Ct. 2455. 49 . Lashbrook v. Lashbroolc, 957 P.2d 326, 328 (Alaska 1998). 50 . Cf. Brady v. Fireman's Fund Ins. Cos., 484 A.2d 566 (D.C.1984) (<HOLDING>). 51 . Wilson, 977 P.2d at 727. 52 . This date
holding that trial court erred by imposing sanctions against attorney without notice and hearing but error was cured by attorneys subsequent challenge to sanctions holding sanctions order not final where the amount of sanctions had not yet been determined holding trial court abused discretion by assessing sanctions without supporting evidence holding that an order imposing sanctions against an attorney for one of the parties in a pending case is final and therefore immediately appealable by the attorney holding that the district court committed reversible error by imposing criminal sanctions in a civil proceeding which did not afford the contemnor the procedural protections the constitution requires for the imposition of criminal contempt sanctions