Sunday, November 24, 2013

Christian v. Mattel, Inc. case brief

Christian v. Mattel, Inc. case brief summary
286 F.3d 1118 (9th Cir. 2003)

The appellant attorney appealed the judgment of the United States District Court for the Central District of California which ordered him to pay, as a Fed. R. Civ. P. 11 sanction, the appellee toy company's attorneys' fees pursuant to a copyright infringement case the attorney filed against the company on behalf of a doll marketer.

The sanctions arose out of the attorney's actions in representing a marketer of dolls against the toy company for copyright infringement. The trial court imposed sanctions after finding that the attorney had filed a meritless claim against the company. The attorney argued, inter alia, that even if the trial court were justified in sanctioning him under Rule 11 based on the complaint and the following motions, its conclusion was tainted because it impermissibly considered other misconduct that could not have been sanctioned under Rule 11, such as discovery abuses, misstatements made during oral argument, and conduct in other litigation.


  • The court of appeals agreed. 
  • The orders clearly demonstrated that the trial court decided, at least in part, to sanction the attorney because he signed and filed a meritless complaint and for misrepresentations in subsequent briefing. 
  • However, the orders, coupled with the supporting examples, also strongly suggested that the trial court considered extra-pleadings conduct as a basis for Rule 11 sanctions. 
  • The trial court did specifically delineate its factual and legal basis for its sanction order. 
  • Therefore, remand was appropriate.
The judgment was vacated and the case was remanded.

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