Saltany v. Bush

Citation. 960 F.2d 1060 (D.C. Cir. 1992)

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Citation960 F.2d 1060 (D.C. Cir. 1992)

Brief Fact Summary.

Saltany appealed a Rule 11 sanction requiring that the plaintiffs pay attorney’s fees to the United Kingdom for the cost of defending a case against President Reagan and the United Kingdom for injuries and losses suffered as a result of the 1986 United States air strike on Libya.

Synopsis of Rule of Law.

A district court must impose a sanction against a party who has violated Rule 11.

Points of Law - Legal Principles in this Case for Law Students.

Courts have the discretion to ignore the law of the case under certain narrow exceptions: if substantially different evidence has been presented, there has been an intervening change in the law, or the prior decision was clearly erroneous and it would work a manifest injustice.

View Full Point of Law

Saltany and 55 other Libyan citizens filed suit against President Reagan and the United Kingdom for injuries and losses suffered as a result of the 1986 United States air strike on Libya. The district court and circuit court dismissed the claims, and the defendants sought Rule 11 sanctions against the plaintiffs’ counsel. The district court did not approve the sanctions and the United Kingdom appealed. The court of appeals reversed the ruling, granting attorney’s fees for the United Kingdom for the cost of defending the case. Saltany appealed.

Issue.

Whether a district court maintains discretion not to impose a sanction against a party who has violated Rule 11?

Held.

No. The judgment is affirmed.

Dissent.

(Wald, J.) The district court judge did not make any necessary findings of fact that found a violation of Rule 11.

Discussion.

A district court does not maintain discretion regarding whether to impose a sanction against a party who violated Rule 11.