In Jones v. Bank of Santa Fe (In re Courtesy Inns, Ltd.), 40 F.3d 1084 (10th Cir.1994), the Tenth Circuit reasoned that 28 U.S.C. 1927, by its very language, authorizes only "courts of the United States" to impose sanctions. Because bankruptcy courts are not such courts, the Tenth Circuit held, they have no authority under 1927 to sanction. The Tenth Circuit felt compelled by 451's plain wording, especially when it viewed that wording in light of the section's legislative history. An amendment in the Bankruptcy Reform Act of 1978 explicitly added "bankruptcy courts, the judges of which are entitled to hold office for a term of 14 years" to the definition contained in 451. Courtesy Inns, 40 F.3d at 1086.