Christian v. Mattel, Inc.

Brief Fact Summary.

Attorney James Hicks brought suit on behalf of Harry Christian (Plaintiff), claiming that Mattel Inc. (Defendant) infringed on Christian’s doll sculpture copyright, despite Defendant’s dolls having been created and copyrighted first.

Synopsis of Rule of Law.

Sanctions under Rule 11 are only granted for misconduct regarding signed pleadings, motions, and other filings

Facts.

Attorney James Hicks brought suit on behalf of Harry Christian (Plaintiff), claiming that Mattel Inc. (Defendant) infringed on Christian’s doll sculpture copyright. Defendant moved for summary judgment and sanctions under Rule 11 because Defendant’s dolls had been created and copyrighted before Defendant’s dolls.

Issue.

Were the sanctions imposed under Rule 11 against Attorney Hicks proper?

Held.

No, the sanctions were not proper because the lower court impermissibly considered conduct outside of signed papers. The case is reversed and remanded for proper consideration.

Discussion.

The Court determined that Attorney Hicks had violated Rule 11 because he filed an objectively frivolous claim on behalf of his client and signed the pleading without uncovering that it was frivolous. However, the lower court impermissibly considered Attorney Hicks’ misconduct in depositions, discovery, hearings, and oral arguments. The misconduct triggering a Rule 11 violation must be properly defined to ensure that the amount in sanctions are appropriate.