Sanctions—Inherent Powers

When a trial court uses its inherent powers to issue pre-trial sanctions against "willful or reckless conduct, especially when combined with frivolousness, harassment, or improper purpose," the Montana Supreme Court reviews these rulings for an abuse of discretion. Boushie v. Windsor, 2014 MT 153, ¶¶ 8, 19, 21, 375 Mont. 301, 328 P.3d 631.