Although the specific burden of proof is unsettled in the Ninth Circuit, the general view is that bad faith or willful misconduct must be proven by clear and convincing evidence. Price v. Lehtinen (In re Lehtinen), 332 B.R. 404, 416 (9th Cir. BAP 2005), aff'd, 564 F.3d 1052 (9th Cir. 2009); In re Frantz, No. 2:15-CV-00460-EJL, 2016 WL 4581405, at *11 (D. Idaho Aug. 31, 2016) (citing Lahiri v. Universal Music & Video Distrib. Corp., 606 F.3d 1216, 1219 (9th Cir. 2010)). While the Supreme Court has warned that "[b]ecause of their very potency, inherent powers must be exercised with restraint and discretion," Chambers v. NASCO, Inc., 501 U.S. 32, 44, 111 S. Ct. 2123, 115 L.Ed.2d 27 (1991), "[s]anctions are justified when a party acts for an improper purpose."

, In re Wallace, 2013 WL 782721 (Bankr. D. Idaho Feb. 27, 2013); In re Daw, 2011 WL 231362 (Bankr. D. Idaho Jan. 24, 2011); In re Hurd, 2011 WL 231362 (Bankr. D. Idaho August 11, 2010). See also In re Frantz, 2016 WL 4581405 (D. Idaho Aug. 31, 2016) (affirming this Court's oral ruling imposing sanctions of over $49,000 on litigants and litigants' counsel under § 105(a) and its inherent powers). --------