U.S. District Judge Clay D. Land has issued a $20,000 sanction for misconduct in a Columbus, Ga., case involving California lawyer and dentist Orly Taitz, a leader of the “birther” movement whose members have challenged President Barack Obama’s U.S. citizenship.

Land issued the 43-page order (pdf) on Tuesday, the third order in which he has taken Taitz to task for filing frivolous litigation and attempting to misuse the federal courts to promote a political agenda that seeks to illegitimize Obama’s presidency.

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