Sunday, November 24, 2013

Frantz v. U.S. Powerlifting Federation case brief

Frantz v. U.S. Powerlifting Federation case brief summary
836 F.2d 1063 (7th Cir. 1987)


CASE SYNOPSIS
Defendant individual sought review of decision, by the United States District Court for the Northern District of Illinois, vacating an award of Fed. R. Civ. P. 11 sanctions in defendant's favor. Defendant federation appealed denial of its request for Fed. R. Civ. P. 11 sanctions.

CASE FACTS
Defendant individual sought review of decision vacating an award of Fed. R. Civ. P. 11sanctions in defendant's favor. Defendant federation appealed denial of its request for Fed. R. Civ. P. 11 sanctions.

DISCUSSION

  • The court held that award of sanctions, under Fed. R. Civ. P. 11, was appropriate because it was clear that plaintiff had no legal for basis for naming defendant individual. 
  • Under Fed. R. Civ. P. 11, plaintiff's counsel was required to do adequate legal research before filing and be aware of the legal rules established by the Supreme Court. 
  • However, the court held that vacating defendant's award of sanctions was inappropriate because judge, in vacating award, failed to provide adequate explanation for that decision. 
  • Exercise of the court's discretion in awarding or vacating sanctions was to be characterized by sound legal principles. 
  • The court held that to avoid Fed. R. Civ. P. 11 sanctions, plaintiff was required only to present an outline of his case before filing the complaint. 
  • However, a claim could be sufficient in form yet still actionable under Fed. R. Civ. P. 11 because counsel failed to conduct a reasonable investigation before filing.
CONCLUSION
The court reversed and remanded. The award of Rule 11 sanctions was appropriate because it was clear that plaintiff had no legal for basis for naming defendant. Plaintiff's counsel was required to do legal research and be aware of legal rules before filing. The decision to vacate the award of sanctions was inappropriate because the district court failed to provide adequate explanation, reflecting sound legal principles, for making that decision.

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