sponte, the general rule is that it must first issue an order to show cause why sanctions should not be imposed to give the lawyer or party an opportunity to explain his or her conduct.”) (citation omitted). Additionally, the district court lacked authority to impose sanctions for pleadings filed in state court prior to removal. See Buster v. Greisen, 104 F.3d 1186, 1190 n. 4 (9th Cir.1997) (explaining that a party may be sanctioned by the district court based on pleading filed in state court only if the party urges the allegations of those pleadings after removal). Finally, Liberty did not engage in sanctionable conduct by amending her client’s complaint to include a civil rights claim. See Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 401-02, 110 S.Ct. 2447, 110 L.Ed.2d 359 (1990) (<HOLDING>). In sum, the district court abused its
recognizing that reasonable time limitations may be placed on the exercise of constitutional rights holding statute of limitations should not be equitably tolled for taxpayer who filed a refund claim after the applicable statute of limitations recognizing that statute of limitations questions may be resolved on a motion to dismiss recognizing that a prefiling investigation that might otherwise be unreasonable may be reasonable where the attorney has limited time to prepare pleadings before the applicable statute of limitations expires recognizing only specific limited forms of pleadings