Young v. City of Providence ex rel. Napolitano

Brief Fact Summary.

The District Court for the District of Rhode Island sanctioned three attorneys for violating Rule 11 of the Federal Rules of Civil Procedure.

Synopsis of Rule of Law.

An attorney does not have to act in bad faith to be sanctioned if the court initiates a Rule 11 inquiry.

Facts.

Young filed suit against Providence for the shooting death of her son by two police officers. The district court determined that the three attorneys governing the case violated Rule 11 of the Federal Rules of Civil Procedure. The district court revoked the pro hac vice status of two of the attorneys who were not members of the state’s bar and censured the other attorney. The three attorneys appealed.

Issue.

Whether an attorney must have acted in bad faith to be sanctioned if the court initiates a Rule 11 inquiry?

Held.

No. The violations are set aside and sanctions are vacated. Rule 11 sanctions were unwarranted because Young’s memorandum did not seek to mislead the judge, nor were any statements in the memorandum false.

Dissent.

(Kennedy, J.) The court fails to establish a clear standard for the type of conduct that warrants a sanction and the required level of bad faith.

Discussion.

Rule 11 of the Federal Rules of Civil Procedure prevents filings made for improper purpose, frivolous arguments, and factual claims without evidentiary support.