I believe the word “frivolous” is in the eye of the beholder, especially when the said beholder is a corrupt judge. All I’ve seen so far are allegations as to “frivolous”, by less than veracious jurists. A monetary sanction does not qualify as a legitimate remedy to assess sanctions, monetary or otherwise. I place the word “frivolous” up there with “lack of standing” as used by alleged judges. Far less than credible in our real world.
Anyone who has followed Orly Taitz and who has read her moronic legal filings and who have watched her demonstrate an almost complete ignorance of judicial processes would not find it at all sinister that Supreme Court clerks tossed her cases into the nearest circular file. These people are not law school instructors. They are not there to hand-hold the Birther Queen through the system. If documents are filed incorrectly or with errors then they get tossed, end of story. And that's almost certainly what happened here.
OK. I was just saying that there are possible reason(s).