In ASAP Copy and Print v. Cannon Business Solutions, Inc., Case No. B232801 (2d Dist., Div. 2 May 1, 2013) (unpublished), the appellate court did reverse a specific OSC re sanctions order based on due process grounds. Although multiple grounds may have supported sanctions, the lower court’s order only cited one specific section, authorizing sanctions up to $1,500. (CCP § 177.5.) Because other potential sections had much variant requirements of higher expsoure, the OSC determination on narrower grounds had to be remanded for a new hearing–maybe on the grounds that permitted higher sanctions, but nonetheless required based on due process principles!