The Fifth Circuit granted a motion for sanctions as to a motion to supplement the record in Texas Alliance for Retired Americans v. Hugh); the key fact involved the duty of candor to the tribunal: “Appellees did not notify the court that their latest motion to supplement the record filed on February 10, 2021 was nearly identical to the motion to supplement the record filed several months ago by the same attorneys, on September 29, 2020. Critically, Appellees likewise failed to notify the court that their previous and nearly identical motion was denied. This inexplicable failure to disclose the earlier denial of their motion violated their duty of candor to the court.” No. No. 20-40643 (March 11, 2021).