on the other hand, insists that sanctions were appropriate because Lederman and Madison were actively involved in the preparation of the misleading declaration, and because Triad’s brief, which did bear their signatures, was misleading inasmuch as it relied heavily on the Mullen declaration. We find that the order imposing sanctions on Lederman and Madison was improper and cannot stand. Until Rule 11 was amended in 1993, subsequent to the Mullen declaration, a bright-line rule applied: Only the individual attorney who actually signed the court paper could be sanctioned because of its contents. Pavelic & LeFlore v. Marvel Entertainment Group, 493 U.S. 120, 110 S.Ct. 456, 107 L.Ed.2d 438 (1989); Giebelhaus v. Spindrift Yachts, 938 F.2d 962, 965 (9th Cir.1991); see also id. at 966 (<HOLDING>). As the Supreme Court has explained: We held
holding that a typewritten name above the signature line is not a signature for frcp rule 11 purposes holding that an award of sanctions under rule 11 survives despite a later determination that the court lacked subject matter jurisdiction holding that rule 11 sanctions are dispositive and thus subject to de novo review holding that an attorneys typewritten name on a pleading is not a signature for purposes of rule 11 and therefore does not subject him to sanctions holding that a motion for rule 11 sanctions is dispositive