Brief Fact Summary.
Ruszala sued Walt Disney World Co. (Disney) for claims referencing Ruszala stealing money from Disney.
Synopsis of Rule of Law.
Federal Rule of Civil Procedure 11 permits a federal court to require a plaintiff who brings a frivolous claim to pay the defendant’s costs and attorney’s fees.
Ruszala worked for Walt Disney World Co. (Disney) when Disney called the sheriff’s office to report that Ruszala was stealing money from the company. Ruszala confessed and was arrested for employment theft after interrogation. Ruszala sued Walt Disney for claims against the incident, including civil rights claims against the county sheriff. The sheriff’s lawyer sought to remove the sheriff from the suit and sought to recover costs from Ruszala for his frivolous claims against the sheriff.
Whether a plaintiff who brings a frivolous claim can be required to pay the defendant’s costs and attorney’s fees?
Yes. Ruszala violated FRCP 11 and an award of the sheriff’s attorney’s fees is the minimum sanction that can be used against Ruszala. Ruszala’s claims against the sheriff were frivolous, even if the claims were not made in bad faith. Ruszala upheld his claims against the sheriff despite knowing that the claims were meritless and receiving two letters from the seriff’s lawyer threatening sanctions if the sheriff was not removed from the suit.
FRCP 11 permits sanctions against a party who files a claim that: (1) has no reasonable basis, (2) whose legal theory is unsupported, and (3) is made in bad faith with an improper motive.