Because clear and convincing evidence is required to justify sanctions for civil contempt, several U.S. Circuit Courts of Appeal — including the 7th Circuit in Maynard v. Nygren, 332 F.3d 462 (2003) — concluded that this heightened burden of proof also applies when a judge dismisses a lawsuit as a sanction for discovery-related misconduct.But the 7th Circuit has “questioned Maynard’s holding on multiple occasions,” Judge Ilana Diamond Rovner explained in Armando Ramirez’s appeal from an …