Ruszala v. Walt Disney World Co.

Brief Fact Summary.

Bill Ruszala (Plaintiff) was arrested for stealing from Walt Disney Co. Plaintiff sued Defendant for false arrest and civil rights violations. Defendant moved for summary judgment and requested Plaintiff pay sanctions in the form of attorney fees and court costs.

Synopsis of Rule of Law.

Pleadings violate Rule 11 when the claims are objectively frivolous and the person signing the pleadings should have been aware that they were frivolous.

Facts.

Walt Disney Co. called the county sheriff’s office to report Bill Ruszala (Plaintiff) for stealing. Corporal Stephens, sent by the Sheriff Beary (Defendant), arrested Plaintiff on the basis that he had confessed to Walt Disney Co.’s security officers. Plaintiff sued Walt Disney Co., its security officer, and Defendant for false arrest and civil rights violations. Defendant moved for summary judgment and requested Plaintiff pay attorney fees and court costs on the basis that the claims against Defendant were frivolous.

Issue.

Was the claim brought against Defendant a violation of Rule 11(b), justifying sanctions in the form of attorney fees and court costs?

Held.

Yes, the claim brought against Defendant was frivolous. Plaintiff is sanctioned in the form of attorney fees and court costs.

Discussion.

The Court determined that Plaintiff’s claims for false arrest and civil rights violations were objectively frivolous because there was overwhelming evidence that the Corporal had probable cause to arrest the Plaintiff. Plaintiff and his attorney should have been aware the claims were frivolous because Plaintiff confessed probable cause in his deposition and Defendant’s attorney sent letters sent to Plaintiff’s attorney stating the claims were frivolous. Continuing to pursue the claims despite this evidence was a violation of Rule 11 justifying sanctions.