Although a district judge properly found a Colorado attorney’s “deliberately dishonest” conduct to be sanctionable, the U.S. Court of Appeals for the Tenth Circuit found it applied too broad a standard when determining the amount of sanctions against her, according to an unpublished opinion released Monday.

U.S. District Judge Daniel Domenico of the District of Colorado previously awarded attorney debt collector Timothy Lamb nearly $33,000 for ”fees incurred related to” a series of actions by Boulder attorney Karen Hammer.