Full opinion text
CARNES, Circuit Judge: No one’s memory is perfect. People forget things or get confused, and anyone can make an innocent misstatement or two. Or maybe even three or four. But not 868 of them. In this case, the plaintiffs attorneys, William and Karen Am-long, filed a sixty-three page errata sheet containing 868 attempted changes to their client’s deposition testimony, which was the sole source of evidentiary support for their client’s claims. The district court exercised its authority under 28 U.S.C. § 1927 to sanction the Amlongs. This is their appeal, or more specifically their second appeal. I. A. In May 1994, Floride Norelus, an illegal immigrant from Haiti, and two of her brothers met with Debra Valladares, a Miami attorney specializing in family law and personal injury litigation. Norelus’ native tongue is Haitian French Creole and she has some difficulty with English, so her brothers translated for her. At the meeting, Norelus told Valladares that she had suffered a nearly year-long ordeal of sexual abuse, including rape, inflicted by Asif Jawaid and Raheel Hameed. Those two men, who were roommates, managed separate Denny’s restaurants where Norelus worked as a bus person, prep cook, and dishwasher. At the meeting one of Norelus’ brothers told Valladares that Jawaid had admitted sexually abusing Norelus. After meeting with Norelus, attorney Valladares visited the two Denny’s restaurants where Norelus had told her that much of the alleged abuse occurred. During these visits, Valladares spoke with a Denny’s employee, Edmond Reed, and a regular patron, John Green, about Norelus’ allegations. Both denied having witnessed the kind of sexual misconduct that Norelus alleged. According to Valladares, Reed did tell her that Jawaid, in Valladares’ words, “definitely had a thing for [Norelus] and that she was like his property.” Green agreed, adding that he felt sorry for Norelus because Jawaid treated her, in Valladares’ words, “as a slave.” At this point, Valladares got help from another attorney, Joseph Chambrot. Chambrot did not investigate Norelus’ allegations, but instead agreed to involve himself with the case because he believed Norelus “looked like a victim” and “looked like someone who had been raped.” Neither Valladares nor Chambrot had any experience with Title VII litigation, so the pair sought the help of William and Karen Amlong and their firm, Amlong & Amlong, P.A. The Amlongs are experienced Title VII attorneys. B. In August 1994, months after the nearly year-long period of alleged abuse had ended, Norelus reported the alleged incidents to the police and to the owners of the Denny’s restaurants. The investigation undertaken by the restaurant owners uncovered no evidence to support Norelus’ claims. Following the police investigation, the State Attorney decided not to prosecute the case due to “inconsistencies and conflicts” in Norelus’ account of the events and a lack of corroborating evidence. The Amlongs knew about the results of the investigation and the State Attorney’s refusal to prosecute before they engaged in the conduct that led to the sanctions against them. Valladares and Chambrot, working from a sample complaint provided by the Am-longs, filed Norelus’ initial complaint on December 19, 1994 in the United States District Court for the Southern District of Florida. In January 1995, the Amlongs assumed primary responsibility for representing Norelus, although Chambrot and Valladares remained minimally involved as co-counsel throughout the litigation. Norelus was deposed for the first time in the present case on August 3, 1995. The Am-longs filed amended complaints on behalf of Norelus on July 27, 1995 and February 12, 1996. The February 12 amended complaint contained claims of sexual harassment, retaliation, battery, unequal pay, invasion of privacy, intentional infliction of emotional distress, false imprisonment, and negligent hiring, training, retention, and supervision. The five defendants were Denny’s, Inc., its parent company, a Denny’s franchisee, and Jawaid and Ha-meed. If the story underlying Norelus’ complaint is true, for nearly a year, from June 1993 to May 1994, she was constantly subjected to sexual harassment and abuse by a relentless aggressor, Jawaid. He was, she alleged, occasionally joined in his gross misconduct by his roommate Hameed. In her complaint Norelus alleged that over an eleven-month period while she worked for Denny’s, she was not only sexually harassed but also assaulted, battered, kidnapped, and raped. She alleged that Jawaid “repeatedly” sexually assaulted her by touching her breasts, genitalia, and buttocks. She alleged that he repeatedly forced her to have oral, vaginal, and anal intercourse with him in various areas of the restaurant, including the men’s bathroom, the walk-in area in front of the freezer room, the stockroom, and in the manager’s office while the office window was covered with a piece of cardboard. She testified in her deposition that Jawaid forced her to have oral sex “almost every day” for eleven months. Norelus claimed that Jawaid offered her job advantages if she went along with his sexual advances and threatened to report her to immigration authorities or to refuse to file necessary immigration paperwork if she did not. Norelus also claimed that when she refused Jawaid’s sexual demands, he assigned her unpleasant duties like cleaning the men’s restroom. She alleged that during one of the times when she was forced to clean the men’s restroom at the restaurant Hameed managed, he forced her to have sex with him there. Most of the conduct Norelus alleged occurred entirely at work, although some of it allegedly began at work and ended at the managers’ home. For example, according to Norelus, Jawaid and Hameed made her leave work early on a few occasions to go to them house for sex. She alleged that on one occasion she was forced to leave work early and was transported to the house where Jawaid and Hameed lived. There, she alleged, the two men restrained her, raped her repeatedly, and forced a hairbrush into her vagina. Most of what allegedly went on, however, occurred at work during regular work hours. Despite Norelus’ allegations of pervasive harassment, gross abuse, and rampant criminal behavior against her, which occurred in various areas of two Denny’s restaurants over the course of almost a year, no one else saw or heard a thing. At least seven of Norelus’ co-workers, whom the Amlongs had planned to call as witnesses in support of her allegations, actually contradicted those allegations under oath when deposed by defense counsel. Those witnesses were specifically asked if they had ever heard Jawaid make any sexual comments to Norelus, if they had ever seen Jawaid touch Norelus in a sexual way, and if they had seen Jawaid touch any female employee in a sexual way. All of them answered “No” or “Never” to those questions. One of those witnesses was a waitress named Rose Boleda, who worked the same shift as Norelus. When asked about the interactions of Jawaid and Norelus, Boleda testified: “I never saw anything out of the ordinary to say that anything was going on.” After giving similar testimony, some of the other witnesses stated that they wondered why Norelus had identified them as having seen or heard something. None of the co-worker witnesses testified to having seen or heard anything improper. Some went further, and based on their experiences with Jawaid expressed doubt that such conduct could have occurred. Rose Boleda testified that when Jawaid would “hear[] the girls talking about something [sexual] he [would] walk[ ] right out. He gets very upset. He doesn’t like that at all, so he would never [engage in the alleged conduct].” When asked about the allegations against Jawaid, Denny’s line cook Evon Martin shook his head and said: “It’s just not him to do that .... He’s not the kind of guy who would talk about sex or mess with people like that.” Martin also testified that he had received a phone call from Norelus telling him that she was suing Jawaid for sexual harassment and wanted to meet with Martin to talk. Martin noted that during their conversation Norelus had complained that “[Jawaid] made me work so hard,” but she said nothing about Jawaid having sexually harassed her. From the deposed witnesses’ descriptions of the restaurants involved, it is inconceivable that gross sexual harassment and misconduct could have occurred on a near-daily basis for nearly a year, as Norelus claimed it did, without any witnesses having seen or heard anything. According to Boleda, there is “no way anything is going to happen in that little tiny restaurant and [some employees are] not going to see what’s going on.” Another waitress, Michele Stewart, explained that “everything is open. Employees are all over the restaurant.” She agreed that “[tjhere’s no way” the conduct Norelus alleged could have occurred without some employee seeing something. Line cook Martin testified that it would be “impossible” for the conduct alleged to occur without people knowing because the restaurant is “too small.” Even the areas of the restaurant that seem the most private, like the restroom or the stockroom, were not completely shielded from view. When cleaning the men’s restroom, which was part of Norelus’ duties as an employee, the typical procedure was to prop the door open with a mop bucket. Even if that was not done, the men’s restroom still did not provide total privacy. According to an employee’s deposition testimony, a person using the pay phone outside the men’s restroom could see inside when the door opened. Once a person could see into the restroom, he could see whether someone was in the stalls because the stall doors did not reach all the way to the ground. Although one stockroom was locked during part of the graveyard shift, it was open during the 7:00 a.m. to 3:00 p.m. shift that Norelus worked. The restaurant stayed “[t]oo busy to keep [the stockroom] locked,” with employees running in and out of it to get supplies throughout the day. The manager’s office was located right beside the employees’ break area and table. When the office door was closed, someone seated at the break table could hear what was going on inside the office if she listened, although what she heard would not be perfectly clear. The door to the walk-in area in front of the freezer had a window in it as well, and unless that window was fogged up because the door had been opened recently, it provided a clear view into the area. And Jawaid himself had little privacy. As manager of the restaurant he was often in demand. One line cook explained in deposition that “[e]very single five minutes [some employee] need[s] something from the manager, where is he going to hide?” With so little private space, if Norelus’ allegations of rampant harassment, sexual misconduct, and assault were true, someone would have seen something. Norelus’ co-workers, who would have seen or heard something, testified under oath that they had not seen or heard anything. After the witnesses the Amlongs planned to call to corroborate Norelus’ allegations failed to do so, counsel for the defendants warned the Amlongs “that the case lacked merit and might result in sanctions.” The Amlongs, however, were undeterred by the complete lack of corroboration and the mountain of evidence contradicting their client’s claims, which the depositions of potential fact witnesses uniformly revealed. No one from the Amlong firm deposed any fact witnesses in this case or ordered transcripts of any depositions that were taken by the defendants until the sanctions hearing that resulted from the submission of the sixty-three page errata sheet. The Amlongs had, however, sent one or two associates to at least ten of the thirteen witnesses’ depositions, and those associates provided the Amlongs with summaries of the testimony from their notes. The more experienced of the two associates expressed her doubts about the case to Karen Amlong who disregarded the associate’s concerns. Norelus herself was never a stable or reliable witness. Her second deposition, which took place during January and February of 1996, spanned eight days. At least one of the Amlongs’ associates attended each session of Norelus’ deposition, although neither of the Amlongs did. During the deposition an interpreter translated the questions into Haitian French Creole for Norelus and translated her answers into English. Throughout the course of the deposition Norelus exhibited emotional and erratic behavior. From the first day of her deposition, Norelus lied. For example, when asked if she knew anyone named Lavictore Remy, Norelus testified that she did not. Later she was forced to admit that Remy was her cousin and that she had falsely used Remy’s name in her application to work at Denny’s. When asked if she had lied, Norelus responded: “Of course. What’s wrong with that?” More troubling testimony from Norelus was to come. At several points during her deposition, she directly contradicted statements she had made in her complaint. For example, in her complaint Norelus alleged that Jawaid had forced her to have oral, vaginal, and anal sex in the walk-in area in front of the freezer. But during deposition she testified that no sex had occurred there. Norelus also alleged in her complaint that Jawaid had forced her to have oral, vaginal, and anal sex in the restroom and in the stockroom and in the manager’s office. But she testified at her deposition that no vaginal or anal intercourse had taken place at any of those locations. Norelus alleged in her complaint that the managers retaliated against her at work after she complained to restaurant authorities about the sexual harassment. But she testified in her deposition that she had not complained until after she resigned from her job, which means that no retaliation could have occurred at work. Norelus also alleged in her complaint that after the managers raped her with a hairbrush, she sought medical attention. But at her deposition Norelus testified that she had not sought medical attention, and in response to other discovery requests of the defendants she was unable to name any health care provider or facility she had visited. During the time period in which Norelus’ deposition was being taken, the Am-longs arranged for her to undergo a polygraph examination. According to Karen Amlong, they arranged for the polygraph in order to probe the truthfulness of Norelus’ claims of abuse. Norelus underwent a second polygraph examination after the last day of her deposition. To conduct the examinations, the Amlongs hired George Slattery, a well respected polygraph examiner who had done work for various law enforcement agencies. Slattery was of the opinion that both examinations showed that, while she was lying about some things, Norelus was telling the truth about her core allegations of sexual abuse. The Amlongs also decided to have a clinical psychologist assess Norelus’ mental state. They selected Dr. Astrid Schutt-Aine, a psychologist who spoke Haitian French Creole, to perform the evaluation. She was of the opinion that Norelus’ symptoms were consistent with those exhibited by people suffering from Post-Traumatic Stress Disorder. The record contains no evidence, however, that Dr. Schutt-Aine formed any opinion about the source or nature of any trauma Norelus had suffered. At this point, the Amlongs decided to continue pursuing the lawsuit. As part of their preparation for trial, they instructed one of their associates to review Norelus’ deposition testimony with her. Norelus’ brother, whom the Amlongs had listed as a potential fact witness in support of her allegations, served as an interpreter. During this process, the associate read aloud to Norelus the questions asked by defense counsel during the deposition. The brother interpreted those questions for Norelus and then interpreted her answers for the associate. The Amlongs’ associate then prepared an errata sheet. The finished product errata “sheet” was actually sixty-three sheets that made 868 changes to Norelus’ deposition testimony. The reason given for more than 500 of the 868 changes to Norelus’ deposition testimony was merely that Norelus “[d]id not understand what was being asked.” The reasons given for most of the other changes in Norelus’ testimony were classified into three broad categories: “poor translation by interpreter,” “clarification of response,” and “refreshed recollection.” At the end of the lengthy errata sheet Norelus signed a sworn statement certifying that she had read the transcript of her deposition and that it “is a true and accurate recording of the proceedings had at the time and place designated with the exceptions, if any, on the ERRATA sheet.” Veda Russo, the office manager for the court reporting service that had transcribed Norelus’ deposition, notarized Norelus signature and the date that she signed it, which was June 14, 1996. By creating “exceptions” to the deposition transcript being “a true and correct recording” of the Norelus’ answers to the deposition questions, the errata document was intended to be, and was, made a part of the deposition. Norelus did not sign the deposition, except by means of the errata document and subject to the massive number of exceptions contained in that document. The first time the defendants heard anything about the errata document was on June 19, 1996, which was after discovery had closed and just three weeks before trial was scheduled to begin. On that date the parties had a conference call and discussed a proposed amended joint pretrial stipulation. Two days later, in a “Motion for Extension of Time to Prepare the Pretrial Stipulation,” the defendants informed the district court that during the June 19 conference call, they “were told for the first time that Plaintiff had filed a 50 to 60 page Errata Sheet making extensive ‘corrections’ to Plaintiffs deposition” and that the defendants had not yet had an opportunity to review the errata sheet. On August 1, 1996, the defendants filed a motion to dismiss the complaint, arguing that the number and nature of the changes demonstrated that Norelus had committed perjury during her deposition. The district court denied the motion, stating that dismissal was an “inappropriate remedy” at that point because dismissal is only appropriate when “the plaintiffs lie is established beyond doubt” and that it was “unclear to the Court at this juncture whether the Plaintiffs original or revised version of the facts constitutes the truth.” Instead of dismissing Norelus’ case, the court ordered her deposition reopened, with Norelus to pay the costs of it. The district court also ordered Norelus to file an appendix to her deposition identifying, describing, and explaining in detail each of the changes made to her testimony in the second deposition. (Apparently, that was never done.) Norelus’ third deposition occurred in September 1996 and lasted three days before it was abruptly ended. Karen Am-long attended this deposition in person. Norelus behaved much as she had in her second deposition. She again had trouble recalling facts, including those contained in the recently submitted errata sheet. Finally, after a heated exchange in which Norelus responded sarcastically to his questions, defense counsel ended the deposition. On October 16, 1996, the district court entered an order making Norelus and the Amlongs jointly responsible for the costs of reopening the deposition. When Norelus and the Amlongs refused to pay those costs, the district court dismissed the lawsuit. Norelus appealed the resulting judgment against her, but we dismissed the appeal because she failed to prosecute it. See Amlong & Amlong, P.A. v. Denny’s, Inc., 500 F.3d 1230, 1236 (11th Cir.2007) (Amlong 7). C. The procedural history of the sanctions proceedings is set out more fully in Am-long I, 500 F.3d at 1236-37, but we will summarize that history before discussing the proceedings that have taken place since we issued our opinion in Amlong I. After the dismissal of Norelus’ complaint, several of the defendants filed motions asking the district court to impose sanctions against Norelus and the Am-longs. At the direction of the district court, a magistrate judge conducted an evidentiary hearing and filed a report and recommendation containing findings of fact and conclusions of law. Id. at 1236. The recommendation was that the district court assess attorney’s fees against Norelus under 42 U.S.C. § 2000e-5(k) but not against the Amlongs. Id. The magistrate judge found that the Amlongs, “from beginning to end, believed in plaintiffs credibility as to the ‘core allegations’ of the lawsuit [] and genuinely believed that plaintiffs claims were meritorious despite plaintiffs inability to testify completely and truthfully about several aspects of her case.” On that basis he concluded “that the Amlong’s conduct did not amount to bad faith conduct justifying sanctions under 28 U.S.C. § 1927.” Id. at 1237. The defendants objected to the report and recommendation and asked the district court to impose sanctions on the Amlongs. Without conducting its own evidentiary hearing, the district court sustained the defendants’ objections. Rejecting the report and recommendation, the court ordered the Amlongs to pay sanctions. The order “required the Amlongs personally to pay,” among other amounts not at issue here, “a total of $389,739.07 to cover attorney’s fees and costs the defendants had incurred after the filing of the errata sheet.” Id. The Amlongs appealed. In Amlong I we concluded that “the district court abused its discretion and clearly erred when it squarely rejected the magistrate judge’s findings of fact and credibility determinations and substituted its own, without hearing so much as a single witness at a sanctions hearing.” Id. at 1251. We reversed and remanded the case to the district court with instructions that it choose one of two options: “It may accept the magistrate judge’s basic findings of fact and then reach its own determination as to whether the [Amlongs’] conduct [warranted sanctions under § 1927]” or, in the alternative, “the district court may, if it so chooses, conduct its own hearing as a prelude to making a new determination.” Id. On remand the district court adopted the magistrate judge’s factual findings and declined to hold its own evidentiary hearing. The court nevertheless reimposed sanctions on the Amlongs, rejecting the magistrate judge’s legal conclusions as based on a flawed understanding of the standard for imposing sanctions pursuant to § 1927. The court viewed the question before it as whether a reasonable attorney would have filed the errata sheet and continued to pursue Norelus’ claims knowing what the Amlongs knew at the time they made and filed the sheet and continued with the case. The court answered that question in the negative, explaining: [The] numerous changes contained in the' errata sheet should have related to the Amlongs that [Norelus] was not able to relate a consistent account of the events underlying her claims. Therefore, the Court finds that the preparation and filing of the Errata Sheet itself, combined with the improper methods of preparation and the factual content of such Errata Sheet, constituted objectively reckless conduct on the part of the Amlongs, which was so egregious that it was tantamount to bad faith. Moreover, the Amlongs[] continued to press forward with their case after the filing of the Errata Sheet and in spite of the fact that [Norelus] continued to evade reasonable inquiry concerning her evolving account of events alleged in this case during her reopened deposition. Taken together, this objectively reckless conduct unreasonably and vexatiously multiplied the instant proceedings. (citations omitted). The district court’s award of sanctions held the Amlongs jointly and severally liable for the defendants’ costs, expenses, and attorney’s fees incurred from the date the errata sheet was submitted until the initial imposition of sanctions by the district court. The sanctions award included the costs, expenses, and fees incurred in connection with the sanctions proceedings. The sanctions amount imposed by the district court following remand totaled $387,738.45. The Amlongs then brought this appeal, contending that the district court abused its discretion in imposing sanctions against them under § 1927. They also contend that, even if the district court did not abuse its discretion by imposing sanctions, it did so by including in the sanctions award the costs, expenses, and fees arising from the sanctions proceedings themselves. II. We review the district court’s imposition of sanctions under 28 U.S.C. § 1927 only for an abuse of discretion. Schwartz v. Millon Air, Inc., 341 F.3d 1220, 1225 (11th Cir.2003). “The application of an abuse-of-discretion review recognizes the range of possible conclusions the trial judge may reach.” United States v. Frazier, 387 F.3d 1244, 1259 (11th Cir. 2004) (en banc). By definition ... under the abuse of discretion standard of review there will be occasions in which we affirm the district court even though we would have gone the other way had it been our call. That is how an abuse of discretion standard differs from a de novo standard of review. As we have stated previously, the abuse of discretion standard allows “a range of choice for the district court, so long as that choice does not constitute a clear error of judgment.” Id.; see also McMahan v. Toto, 256 F.3d 1120, 1129 (11th Cir.2001) (“[U]nder an abuse of discretion standard there will be circumstances in which we would affirm the district court whichever way it went.”); In re Rasbury, 24 F.3d 159, 168 (11th Cir.1994) (“Quite frankly, we would have affirmed the district court had it reached a different result, and if we were reviewing this matter de novo, we may well have decided it differently.”). “[W]hen employing an abuse-of-discretion standard, we must affirm unless we find that the district court has made a clear error of judgment, or has applied the wrong legal standard.” Frazier, 387 F.3d at 1259 (citing Maiz v. Virani, 253 F.3d 641, 662 (11th Cir.2001)). III. A. 28 U.S.C. § 1927 authorizes federal courts to require any attorney “who so multiplies the proceedings in any case unreasonably and vexatiously ... to satisfy personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” We have long held that “the provisions of § 1927, being penal in nature, must be strictly construed.” Peterson v. BMI Refractories, 124 F.3d 1386, 1395 (11th Cir.1997) (citing Monk v. Roadway Express, Inc., 599 F.2d 1378, 1382 (5th Cir.1979)), aff'd sub nom., Roadway Express, Inc. v. Piper, 447 U.S. 752, 100 S.Ct. 2455, 65 L.Ed.2d 488 (1980). The statute’s plain language sets forth three requirements to justify an imposition of sanctions: (1) an attorney must engage in “unreasonable and vexatious” conduct; (2) such “unreasonable and vexatious” conduct must “multiply] the proceedings;” and (3) the amount of the sanction cannot exceed the costs occasioned by the objectionable conduct. McMahan, 256 F.3d at 1128 (citing Peterson, 124 F.3d at 1396). The Amlongs’ submission of the novella-length errata sheet making a slew of material changes to their client’s deposition testimony was improper. See Hambleton Bros. Lumber Co. v. Balkin Enters., Inc., 397 F.3d 1217, 1225 (9th Cir.2005) (upholding a district court’s judgment to strike an errata sheet listing twenty-seven changes, noting that “Rule 30(e) is to be used for corrective, and not contradictory, changes”); Garcia v. Pueblo Country Club, 299 F.3d 1233, 1242 n. 5 (10th Cir. 2002) (“We do not condone counsel’s allowing for material changes to deposition testimony and certainly do not approve of the use of such altered testimony that is controverted by the original testimony.”); Thorn v. Sundstrand Aerospace Corp., 207 F.3d 383, 388-89 (7th Cir.2000) (explaining that an errata sheet effecting “a change of substance which actually contradicts the transcript is impermissible unless it can plausibly be represented as the correction of an error in transcription, such as dropping a ‘not’ ”); Greenway v. Int’l Paper Co., 144 F.R.D. 322, 325 (W.D.La.1992) (“[Rule 30(e)] cannot be interpreted to allow one to alter what was said under oath. If that were the case, one could merely answer the questions with no thought at all then return home and plan artful responses. Depositions differ from interrogatories in that regard. A deposition is not a take home examination.”); but see Podell v. Citicorp Diners Club, Inc., 112 F.3d 98, 103 (2d Cir.1997) (“[T]he language of [Rule 30(e)] places no limitations on the type of changes that may be made, nor does [Rule 30(e)] require a judge to examine the sufficiency, reasonableness, or legitimacy of the reasons for the changes — even if those reasons are unconvincing.” (quotation marks and alterations omitted)); Reilly v. TXU Corp., 230 F.R.D. 486, 487-90 (N.D.Tex.2005) (reviewing the various approaches for interpreting the allowable scope of Rule 30(e) changes and ultimately adopting a broad interpretation “consistent with the plain language” of Rule 30(e), allowing any changes, “in form or substance” under Rule 30(e)); cf. EBC, Inc. v. Clark Bldg. Systems, Inc., 618 F.3d 253, 268 (3d Cir.2010) (“We therefore hold that when reviewing a motion for summary judgment, a district court does not abuse its discretion under Rule 30(e) when it refuses to consider proposed substantive changes that materially contradict prior deposition testimony, if the party proffering the changes fails to provide sufficient justification. At the same time, we emphasize that courts may, in their discretion, choose to allow contradictory changes (and implement the remedial measures discussed above) as the circumstances may warrant.”). One circuit has gone so far as to call the creation of an errata sheet making substantive changes a “foolish tactic.” Thorn, 207 F.3d at 388-89. In the present case, the magistrate judge who conducted the evidentiary hearings of the defendants’ motion for sanctions found that the procedures used to prepare the errata sheet, “i.e., translating through plaintiffs brother and possible explanations of questions by plaintiffs counsel” were also improper. As the magistrate judge found and no one (with the possible exception of the dissenting judge on this panel) seriously contests, the improper submission of the massive errata document rendered the eight days spent on Norelus’ deposition a waste of time and money to say nothing of the time the attorneys were forced to spend on the issues created by the document itself. The Amlongs’ decision to press on with Norelus’ claims after the creation of the errata document wasted more time and money. Together, the submission of the errata document and the continued pursuit of Norelus’ claims after-wards unquestionably prolonged and multiplied the proceedings. The question is whether under the circumstances of this case the district court abused its discretion in finding that it was done “unreasonably and vexatiously.” 28 U.S.C. § 1927; see Amlong I, 500 F.3d at 1242. An attorney multiplies court proceedings “unreasonably and vexatiously,” thereby justifying sanctions under 28 U.S.C. § 1927, “only when the attorney’s conduct is so egregious that it is ‘tantamount to bad faith.’ ” Amlong I, 500 F.3d at 1239 (quoting Avirgan v. Hull, 932 F.2d 1572, 1582 (11th Cir.1991)). The standard is an objective one turning “not on the attorney’s subjective intent, but on the attorney’s objective conduct.” Id. In Am-long I, we said that “objectively reckless conduct is enough to warrant sanctions even if the attorney does not act knowingly and malevolently.” Id. at 1241. We compare the conduct at issue with how a reasonable attorney would have acted under the circumstances. The Amlongs’ conduct was at least objectively reckless. The Amlongs’ attempt to alter their client’s deposition testimony in 868 ways was of a piece with their conduct throughout the litigation. As the magistrate judge found, they had nothing to base Norelus’ claims on other than her “own changing testimony ... which was totally or nearly totally discredited by plaintiffs numerous lapses of memory, outright lies, and outlandish comments made during her deposition.” As the litigation unfolded, all of the witnesses who should have seen or heard something if the claims had any basis in fact not only failed to support her incredible story but actually gave deposition testimony contradicting it. Still, like Ahab hunting the whale, the Amlongs relentlessly pursued the claims. All the while they blinded themselves to as much of the contradictory evidence as they could. They deliberately did not obtain the deposition testimony of any of Norelus’ co-workers who would have seen or heard something had anything improper occurred. They did not concern themselves with that testimony, according to Karen Amlong, because they assumed all of the witnesses, except for their client, were either lying or simply could not remember witnessing the gross sexual harassment inflicted on her. When the truth was thrust in the Am-longs’ faces, they stubbornly ignored it and kept on litigating. They knew that the State Attorney’s Office had refused to file criminal charges because it had found “inconsistencies and conflicts” in Norelus’ allegations. They knew, given the nature of her allegations, that if Norelus’ story about the extreme and extensive crimes against her were true, there would have been a lot of corroborating evidence from others who were present at the two small restaurants during those eleven months, but there was none. They knew that the testimony of every witness who should have supported Norelus’ story, if it were true, either failed to do so or in many cases actually contradicted it. They knew that the more experienced associate they had sent to monitor the depositions of other employees came back with misgivings about the validity of their case. They knew that their client had responded to a deposition question about whether she had lied with her own question: “Of course, what’s wrong with that?” And they knew, or should have known, that submitting an errata document that made 868 changes in their client’s deposition testimony would effectively destroy any credibility she might otherwise have had. They knew all of this in light of their significant experience as Title VII lawyers. Karen Amlong, who was admitted to practice in 1979, testified in the sanctions hearing that she personally had handled about fifty sexual harassment cases. She also estimated that about three-fourths of the cases handled by the Amlong law firm, in terms of both time and income, were employment cases and that half of those involved sexual harassment claims. Under all of the circumstances, a reasonable attorney would have known that any road paved with the truth could not lead to judgment for Norelus. Yet, in spite of everything, the Amlongs charged ahead, apparently determined to pursue the case at all costs. At the sanctions hearing, Karen Amlong defended the decision to continue to press Norelus’ claims even after her disastrous deposition performance. She testified that her belief in the truth of Norelus’ allegations was bolstered by, and consistent with, the results of two polygraph examinations and a clinical psychologist’s conclusions following an examination of Norelus. According to the Amlongs, those examinations, which they arranged, demonstrate that their continued pursuit of Norelus’ claims was without the recklessness that justifies sanctions under § 1927. We disagree. It can be debated whether the polygraph examinations indicate that the Amlongs believed they were litigating the case in good faith. Karen Am-long testified that they sometimes arranged for polygraph examinations of their clients for “ethical reasons” and as a form of “self-protection.” That testimony suggests that the Amlongs banked the polygraph examinations for use in fending off sanctions. It is true that to some extent the Amlongs’ subjective state of mind is relevant to whether sanctions should be imposed because conduct is more likely to be “unreasonable and vexatious” if it is done with a malicious purpose. See Amlong I, 500 F.3d at 1241 n. 1 (“[A] determination of whether an attorney’s conduct was objectively reckless, or tantamount to bad faith, may be aided by an examination of the attorney’s state of mind.”). However, we have held that “for purposes of § 1927, bad faith turns not on the attorney’s subjective- intent, but on the attorney’s objective conduct.” Id. at 1239; see also Braley v. Campbell, 832 F.2d 1504, 1512 (10th Cir.1987) (en banc) (“Subjective good faith ought not to be an infinitely expansive safe harbor to protect an attorney who brings an action that a competent attorney could not under any conceivable justification reasonably believe not frivolous.”). Even if the polygraph results did allay the Amlongs’ own well-founded fears about whether their client was telling the truth, those results could not have justified the belief, if they had one, that their client’s case had a snowball’s chance of making it to a favorable judgment. Opinions based on polygraph examinations are seldom, if ever, admissible into evidence. See United States v. Henderson, 409 F.3d 1293, 1301—04 (11th Cir.2005) (upholding a district court’s decision to exclude polygraph results under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993)). We have never held that it is an abuse of discretion to exclude the opinion of a polygraph examiner. Id. at 1303. To no one’s great surprise, the district court ruled in this case that any evidence relating to the polygraph examinations would not be admissible at trial. No reasonable attorney would base a case on the unreasonable expectation that a polygraph examiner’s opinion about whether someone was telling the truth would be admitted into evidence. That is especially true where there are many witnesses who, if the client’s story were true, would have seen or heard something, and all of them testified under oath that they saw and heard nothing. Besides, even if the district court had allowed evidence about the polygraph examinations, “the only thing the polygraph examination ‘proves’ is that the examinee believes her own story.” Amlong I, 500 F.3d at 1269 n. 30 (Hill, J., dissenting); see also Julie A. Seaman, Black Boxes, 58 Emory L.J. 427, 475 (2008) (“A witness might believe that she is testifying truthfully but be mistaken or perhaps delusional; it is sometimes assumed that even a foolproof lie detector would not detect such untruths.” (footnotes omitted)). The same can be said for the psychologist’s opinion that Norelus’ symptoms were consistent with those exhibited by people suffering from Post-Traumatic Stress Disorder. At most that opinion is evidence that Norelus believed she had been subjected to some kind of trauma by someone at some time. It does not prove that any of Norelus’ allegations in this case are true. See Amlong I, 500 F.3d at 1269 n. 30 (Hill, J., dissenting). Following the polygraph and psychologist examinations, the Amlongs compiled and then submitted the errata document making 868 changes to Norelus’ deposition testimony. As we have already mentioned, the reason given for more than 500 of the 868 changes to Norelus’ deposition testimony was merely that Norelus “[d]id not understand what was being asked.” The remaining changes were classified mainly in three other broad categories: “poor translation by interpreter,” “clarification of response,” and “refreshed recollection.” But Norelus, or her counsel, could have prevented any problems caused by her lack of understanding about what was being asked or by poor translation. They chose her interpreter. And at the beginning of her deposition, she was asked to listen to the question in English and then wait for the interpreter to ask it in Haitian Creole, her native language. Norelus agreed to do that. She was also instructed: “If at any time you don’t understand my question, would you please advise me of that ... [a]nd I’ll try and rephrase it.” Norelus agreed to do that. The record casts serious doubt on Norelus’ alleged misunderstanding of the questions. Several “misunderstood” questions called for yes or no answers, and Norelus did not seem to have trouble answering those questions when they were asked diming the deposition. To take only one of many examples, she was asked a fairly simple question: whether a former coworker named David Hill had ever come to her house before she stopped working at Denny’s. Without any apparent hesitation, she responded “yes.” In the errata changes, however, the “yes” became a “no.” Some of the changes made by the errata document were pure additions. Events and facts Norelus could not remember during her deposition were described by her in vivid detail in the lengthy errata document where they were often characterized as “refreshed recollections” without any indication as to who or what had refreshed her memory. A few examples will serve to illustrate. At her deposition, Norelus testified that she could not remember what type of car she rode in on the way to Jawaid and Hameed’s house the time they allegedly raped her and inserted a hairbrush into her vagina. She also testified that she could not remember the route they had taken to get to the house, the color of the hairbrush, the material out of which it was made, or whether she rode to their house in the same car that time as she had on other occasions. In the errata document, however, Norelus recalled that the car was a cream-colored, four-door Jaguar; she also recalled the route well enough to provide exact driving directions to the house, including street numbers and which direction to turn on which streets; she remembered the hairbrush was light-to-medium brown and made of wood; and she knew that on different occasions she had ridden to Jawaid and Hameed’s house in three different cars. Between her deposition and the submission of the errata sheet Norelus apparently had the chance to “remember” new information about all kinds of things. At her deposition, when asked where specifically in the men’s restroom Jawaid had forced her to perform oral sex on him, Norelus answered that she did not remember. In the errata document, however, she recalled that he forced her to do it “in the stall.” During her deposition Norelus testified that she did not remember anything she had told the police about being assaulted. By the time the errata document was created, she was certain that she had told the police that her managers had sexually assaulted her. When asked at her deposition why she would use the back door at work Norelus stated, “Sometimes I just use it.” In the errata document, however, she changed that answer to: “I used the back door to leave the restaurant only when Asif took me to his house.” Similarly, during her deposition, Norelus denied that Jawaid had ever forced her to have sex “from the back,” while alleging in the errata document that the sexual encounters between Jawaid and Norelus involved “always vaginal, and sometimes anal sex, too.” And on and on it went. Karen Amlong testified that the Am-longs’ purpose in submitting the novella-length errata sheet was “not to hide things from people, but to make full disclosure” in order to “do the best job [they] could to present as honestly as [they] could what the truth was.” This is a novel proposition: following a lengthy period of discovery and shortly before trial, after their client has given testimony, much of which harms her case as much as helps it, and after the many witnesses who could have corroborated her story have instead contradicted that story, it shows good faith for attorneys to change their client’s deposition testimony in nearly nine hundred ways. Regardless of why the Amlongs created the errata document and injected it into the case, their conduct was improper. Their actions are not the result of ineptitude. We cannot excuse as incompetence a deliberate action of this magnitude committed by attorneys seasoned in Title VII litigation. Tellingly, the Amlongs, who have touted their expertise in litigating this type of case, have never suggested in defense of their actions that they were inept. As the magistrate judge found, only Norelus’ own testimony supported her claims, and the submission of the errata document rendered that testimony useless. The district court did not abuse its discretion when it found that “[no] reasonable attorney would have thought it proper to file such an errata sheet” with a view toward continuing to litigate this case. That is true even if that lawyer subjectively believed his client was telling the truth about her claims. The Amlongs compounded the impropriety of submitting the errata document by continuing to pursue the litigation of Norelus’ claims after submitting it. The magistrate judge found as a fact that: [Norelus] presented only her own changing testimony, without corroboration or support from any other witnesses or sources, which was totally or nearly totally discredited by [Norelus’] numerous lapses of memory, outright lies, and outlandish comments made during her deposition — even if made in anger or frustration. Even [Norelus’] own testimony became useless after she filed the lengthy errata sheet leaving her open to further impeachment during her reopened deposition.... Adopting those findings, the district court reasoned that because Norelus’ own testimony was the only evidence supporting her claims, and because the errata document rendered that testimony “useless,” the Amlongs’ continued “vigorous[ ]” litigation of Norelus’ claims following submission of the lengthy errata document was objectively reckless conduct that unreasonably and vexatiously multiplied the proceedings. It was entirely reasonable for the district court to conclude that the Amlongs acted with objective recklessness when they created the errata document and then continued to pursue Norelus’ claims after the creation and submission of that document had made her claims untenable. That finding is certainly not outside “the range of possible conclusions” permitted under the abuse of discretion standard of review. Frazier, 387 F.3d at 1259. We have previously explained that “[w]hen it becomes apparent that discoverable evidence will not bear out the claim, the litigant and his attorney have a duty to discontinue their quest.” Avirgan, 932 F.2d at 1582 (citations omitted). The Am-longs refused to discontinue their quest for a judgment even after the sole source of evidentiary support for their client’s claims had been rendered useless by the errata document. The district court did not abuse its discretion in concluding that the Amlongs engaged in objectively reckless conduct. The district court’s denial of the defendants’ motion to dismiss following the submission of the errata document does not place that court’s finding that the Am-longs’ conduct was objectively reckless beyond the pale of permissible conclusions it could reach. Frazier, 387 F.3d at 1259; cf. Blue v. U.S. Dep’t of Army, 914 F.2d 525, 535 (4th Cir.1990) (“As a matter of law there is no requirement that a party move for summary judgment as a precondition to the recovery of sanctions. Numerous courts have awarded sanctions to prevailing defendants in Title VII cases despite the fact that plaintiffs were allowed to present their cases.”). The district court did not act inconsistently when it later decided to impose sanctions. When ruling on the motion to dismiss, the court was considering a different issue from the one the Amlongs themselves considered in deciding whether to submit the voluminous errata document and then charge ahead with Norelus’ claims. The issue the motion to dismiss presented the district court was whether to dismiss Norelus’ claims at that stage or instead to permit inquiry into the reasons the Amlongs and Norelus had asserted for changing her testimony. The questions the Amlongs faced were different: (1) whether it was reasonable to make 868 changes, many of them substantive, to their client’s deposition testimony just three weeks before the scheduled trial in the face of a mountain of evidence that her allegations were not true and would never be believed by a factfinder; and (2) whether it was reasonable to continue litigating her claims, which had been left without any credible support due to the creation and submission of the errata document. Attorneys are charged with knowing more about their case, about their client’s various stories, about the contradictions in their client’s testimony, and about the testimony of all the potential witnesses than a busy district court judge with a heavy docket can be expected to know. We refuse to require district courts to dismiss a case at the earliest possible opportunity or lose their authority to impose sanctions under § 1927. We give district courts latitude in exercising their authority to manage litigation instead of looking for a chance to say “gotcha” procedurally. In their final attempt to avoid § 1927 sanctions altogether, the Amlongs argue that two of our earlier opinions, Schwartz v. Millon Air, Inc., 341 F.3d 1220 (11th Cir.2003), and Hudson v. Int’l Computer Negotiations, Inc., 499 F.3d 1252 (11th Cir.2007), “lead inevitably to the conclusion that the lower court’s decision must be reversed as an abuse of discretion.” Neither leads inevitably or otherwise to that conclusion. In Schwartz, we reversed the district court’s imposition of § 1927 sanctions on non-Spanish speaking American attorneys who had represented Ecuadorian clients, with whom they had never met, in personal injury litigation arising out of an airplane crash in Ecuador. 341 F.3d at 1223. An Ecuadorian attorney had referred the cases to the American attorneys. Id. After dismissing the eases, which had proved to be fraudulent, the district court sanctioned the American attorneys because it determined that they had “failed to conduct a proper investigation before filing the complaints and missed later suggestions of meritlessness.” Id. at 1224. The heart of the district court’s decision to impose sanctions was its conclusion that the American attorneys’ “complete reliance” on the Ecuadorian attorney to investigate the facts of the case “was unreasonable and a breach of the duty to investigate.” Id. We reversed, observing that “[tjhis case involves special circumstances” and concluding that, in light of those special circumstances, “we cannot conclude that Appellants acted much (if at all) outside of the range of reasonable conduct by relying upon the representations of ... the duly licensed Ecuadorian counsel,” who “was not obviously unworthy of belief.” Id. at 1226. The Amlongs contend that Norelus’ case resembles Schwartz because her case also presented “special circumstances,” id., including “foreign language and foreign culture difficulties.” The magistrate judge made no mention of language or cultural difficulties in his report and recommendation. Faced with that fact, the Amlongs venture beyond that document in search of support for their position, citing portions of our decision in Amlong I, 500 F.3d at 1247-48, as establishing that “[t]he language and cultural difficulties ... were a recurring problem throughout the litigation.” The Amlongs argue that Amlong I’s factual account binds all proceedings in this case following that decision, including this appeal, because that factual account is now the law of the case. We disagree. It is true that “[u]nder the ‘law of the case’ doctrine, the findings of fact and conclusions of law by an appellate court are generally binding in all subsequent proceedings in the trial court or on a later appeal.” Heathcoat v. Potts, 905 F.2d 367, 370 (11th Cir.1990) (citation and quotation marks omitted); see also Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1289, 1291 (11th Cir.2005) (“The [law-of-the-ease] doctrine operates to preclude courts from revisiting issues that were decided explicitly or by necessary implication in a prior appeal.”). The doctrine applies to those issues that were decided “either explicitly or by necessary implication” in the earlier appeal. United States v. Jordan, 429 F.3d 1032, 1035 (11th Cir.2005). At first glance, that would seem to make the Amlong I panel’s recitation of facts binding on the district court and on us in this appeal, but what appears at first glance does not always withstand closer scrutiny. The mandate rule is a “specific application of the ‘law of the case’ doctrine” requiring that “[a] trial court, upon receiving the mandate of an appellate court, may not alter, amend, or examine the mandate, or give any further relief or review, but must enter an order in strict compliance with the mandate.” Piambino v. Bailey, 757 F.2d 1112, 1119-20 (11th Cir.1985) (collecting cases describing contours of the mandate rule). In Amlong I we issued these specific instructions mandating what the district court could and could not do when it got the case back: On remand, the district court need not conduct a new hearing. It may accept the magistrate judge’s basic findings of fact and then reach its own determination as to whether the [Amlongs’] conduct was objectively unreasonable and vexatious. Alternatively, the district court may, if it so chooses, conduct its own hearing as a prelude to making a new determination. Our holding is simply this: the district court abused its discretion and clearly erred when it squarely rejected the magistrate judge’s findings of fact and credibility determinations and substituted its own, without hearing so much as a single witness at a sanctions hearing. 500 F.3d at 1251. It would be passing strange for the Amlong I panel to have made its own extensive findings of fact, intending to bind the district court under the law of the case doctrine, while at the same time mandating that the district court was required to either “accept the magistrate judge’s basic findings of fact” or “conduct its own hearing” before making its own findings of fact. Id. What would have been the point of that mandate if our opinion had already found the facts in a way that bound the parties and the district court? When viewed through the lens of Amlong I’s actual instructions and mandate, the factual narrative contained in that opinion, including its discussion of linguistic and cultural problems, is properly viewed not as a pronouncement of findings of fact that controlled the future proceedings in the case but instead as background information presented in the light most favorable to the magistrate judge’s ultimate recommendations to the district court. Seen in that light, Amlong I’s factual narrative did not operate as law of the case to bind the district court on remand or us in this appeal. Our conclusion about this keeps the factfinding function in this case where it belongs — in the district court, not in this Court. Pullman-Standard v. Swint, 456 U.S. 273, 291-92, 102 S.Ct. 1781, 1791-92, 72 L.Ed.2d 66 (1982) (“[Fjactfinding is the basic responsibility of district courts, rather than appellate courts.” (alteration in original) (quotation marks omitted)); United States v. Barnette, 10 F.3d 1553, 1558 (11th Cir.1994) (“It is not an appellate court’s role to find facts.”). In any event, even accepting the Am-longs’ contention that Norelus’ Haitian background created serious linguistic and cultural problems, Schwartz still does not require us to reverse the district court’s decision to impose § 1927 sanctions on the Amlongs. The district court in Schwartz sanctioned the attorneys in that case “based upon [their] failure to investigate more thoroughly their clients’ claims.” 341 F.3d at 1226. We reversed the district court’s imposition of sanctions because under the “special circumstances” of that case, which included “great distances across international borders,” “foreign languages and foreign cultures,” “medical records and a great many clients,” it was not “unreasonable — to the point of willful abuse and bad faith — for American counsel to rely upon others (especially other legal counsel) who were fluent in Spanish and familiar with local customs in Equador and who were on the spot to conduct the investigation.” Id. Norelus’ case did not involve those special circumstances: Her case arose in Florida; the potential witnesses were located in Florida; the case involved only a single client; and it did not involve a voluminous collection of documentary evidence written in a foreign language. Despite those key differences in the two cases, the Amlongs argue that their actions compare favorably to those of the attorneys in Schwartz because their belief in Norelus’ veracity was consistent with the views of Valladares (Norelus’ initial attorney), Chambrot (the second attorney to represent her), the polygrapher, and the psychologist, whereas the Schwartz attorneys had relied only on an Ecuadorian lawyer who appeared to be worthy of belief, see Schwartz, 341 F.3d at 1226. That argument fails to grasp the key distinction between the two cases, which is that Schwartz concerned primarily whether the attorneys in that case had failed to fulfill their duty to investigate when they relied on the Ecuadorian attorney to investigate the claims for them. While the Amlongs’ investigatory techniques certainly left much to be desired, the district court did not sanction them for inadequately investigating Norelus’ claims. Instead, it sanctioned them for improperly submitting an errata document, which obliterated the only useful source of evidentiary support for Norelus’ claims, and then pressing forward with the case anyway. The fact that the Amlongs’ assessment of Norelus’ veracity may have been consistent with the beliefs of four people, none of whose beliefs were admissible evidence, does not change the fact that, from the point when they submitted the massive errata document forward, the Amlongs were pursuing a case that no longer had any useful evidentiary support. The Amlongs’ reliance on Hudson is also misplaced. In that case, we affirmed the district court’s refusal to impose § 1927 sanctions on Hudson’s attorneys, Hudson, 499 F.3d at 1266, stating that “while Hudson’s case was weak, it was not ‘so without circumstantial foundation’ as to render it frivolous” and therefore sanctionable pursuant to § 1927. Id. at 1265. The Amlongs urge us to reverse the imposition of sanctions against them because, in their view, Norelus’ case, like Hudson’s, had enough “circumstantial foundation” to rule out § 1927 sanctions. As the foundation for Norelus’ claims, the Amlongs again assert that four other people believed in her veracity. As we have said before, “determinations regarding frivolity are to be made on a case-by-ease basis.” Id. at 1262 (quoting Cordoba v. Dillard’s, Inc., 419 F.3d 1169, 1177 (11th Cir.2005) (quotation marks, emphasis, and brackets omitted)). That said, the comparison between Norelus’ case and the case underlying the Hudson decision is not even close. Hudson alleged that his supervisor, Auer, fired him because of his depression or because of his inquiries into the long term benefits available under International Computer Negotiation’s insurance policy. Id. at 1257. Hudson and Auer agreed that about nine weeks before he was terminated they had a brief conversation about Hudson’s depression. Id. at 1265. Hudson’s speculation that the office manager, Rosenblum, had told Auer about his insurance inquiries, made a mere ei