An El Paso attorney seeking a rehearing on a client's life insurance claim was given a sanction warning by the U.S. Court of Appeals for the Fifth Circuit for his comments about the court's staff attorneys.

Michael T. Milligan, a bar member since 1967, criticized the court's staff attorney's office after a Fifth Circuit three-judge panel affirmed the trial court's judgment in favor of the insurance company in St. Pierre v. Standard Insurance.