Frantz v. U.S. Powerlifting Federation

Brief Fact Summary.

The court of appeals issued Rule 11 sanctions against Frantz’ legal counsel for failing to ensure that the complaint was well grounded in law. 

Synopsis of Rule of Law.

To avoid Rule 11 sanctions, a party must perform legal research and be aware of legal rules prior to filing a complaint. 

Facts.

Two weightlifters filed suit against the International Powerlifting Federation, the United States Powerlifting Federation (USPF), and the president of the USPF. When the complaint was dismissed against the USPF and its president, Frantz filed an amended complaint against USPF alone. The court awarded the president attorney’s fees that were later vacated by the judge. The president of USPF appealed. 

Issue.

Whether a party must perform legal research and be aware of legal rules prior to filing a complaint?

Held.

Yes. In a complaint that pleads multiple claims, each claim must be grounded in a factual basis as if each claim was being pleaded on its own. In this case, legal counsel was not aware of each fact that supported the multiple claims, rendering Rule 11 sanctions appropriate. The rulings of the lower courts are reversed and remanded.

Discussion.

Legal counsel is required to be aware of current Supreme Court rulings and legislation that can affect a party’s claim. The filing of a frivolous claim can result in Rule 11 sanctions by the court.