Saltany v. Reagan

Brief Fact Summary.

The United Kingdom appealed a judgment denying the imposition of Rule 11 sanctions and sought attorney’s fees 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.

Facts.

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, requesting attorney’s fees for the cost of defending the case.

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 reversed and remanded. The United Kingdom’s request for attorney’s fees should be granted. The district court found that the plaintiffs violated Rule 11 by pursuing a case they knew they would not win, and the court erred by not imposing sanctions.

Discussion.

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