In People v. Muhammad (2003) 108 Cal.App.4th 313, the Court addressed the issue of sanctions under section 177.5. Muhammad involved a Wheeler motion (People v. Wheeler (1978) 22 Cal.3d 258), when someone files a Wheeler motion, he asserts that the prosecutor had used peremptory challenges to exclude prospective jurors based on group bias. (See Wheeler, supra, 22 Cal.3d at pp. 276-277.) Race-based use of peremptory strikes violates the federal constitutional guaranty of equal protection of the law, as held in Wheeler, supra, 22 Cal.3d 258. The trial court in People v. Muhammad found that the prosecutor violated Wheeler and declared a mistrial. (Muhammad, supra, at pp. 317-318.) It then issued an order to show cause why sanctions should not be imposed under section 177.5. One of the arguments raised by the prosecutor in opposing the imposition of sanctions was that "section 177.5 does not apply to an advocacy situation such as jury selection ... ." (Muhammad, supra, at p. 318.) The trial court rejected that and the prosecutor's other arguments and imposed sanctions. (Ibid.) On appeal, the court reiterated that under section 177.5, an attorney may be sanctioned for violating a lawful court order. (People v. Muhammad, supra, 108 Cal.App.4th at pp. 323-324.) Because there was no court order that the prosecutor violated, the appellate court concluded that the sanction order had to be reversed. (Id. at p. 325.) The court noted: "Certainly if a court admonishes counsel that a repetition of specific conduct will result in a monetary sanction, that statement is tantamount to an order not to repeat the conduct, and should suffice under section 177.5." (Ibid.) In determining what a trial court must do "to preserve the option of imposing a monetary sanction" for a Wheeler violation, the court noted that based on its "reading of Wheeler cases in the literature, it appears that the issue usually is raised more than once if it is raised at all, thus giving the court an opportunity to issue an appropriate admonition." (Id. at pp. 325-326.)