2.5 Inherent Powers

• Library: Attorney Fees and Sanctions - Virginia and Federal Courts (Virginia CLE) (2016 Ed.)

2.5 INHERENT POWERS

The trial court has the inherent power to supervise the conduct of attorneys practicing before it and to discipline any attorney who engages in misconduct. ¹²⁷

The Virginia Supreme Court noted in Nusbaum v. Berlin ¹²⁸ that

[n]early two centuries ago, in Anderson v. Dunn, ¹²⁹ the Supreme Court of the United States stated, "Courts of justice are universally acknowledged to be vested, by their very creation, with power to impose silence, respect, and decorum, in their presence, and submission to their lawful man-dates." ¹³⁰ These "inherent powers" are "governed not by rule or statute but by the control necessarily vested in courts to...