A federal appeals court has vacated $24,400 in sanctions against two law firms because a district judge ordered the sanctions without a finding of bad faith and gave the firms no chance to respond.

Southern District Judge Deborah Batts (See Profile) in 2011 had ordered Vermont’s Langrock Sperry & Wool and Virginia’s Lankford & Reed to pay attorney fees and costs to Cleary Gottlieb Steen & Hamilton because the firms were four days late in filing paperwork on motions to dismiss in the case.