Ruszala v. Walt Disney World Co.
132 F.Supp.2d 1347 (M.D. Fla. 2000)
Facts: In January 1996, Corporal Robert Stephens (“Stephens”) of the Orange County Sheriff’s Office was called to Walt Disney World in response to a reported crime. Upon arriving, he was informed that Mr. Ruszala (“plaintiff”) had been employed in one of the Walt Disney World restaurants and that he had been progressively stealing money from the register. Plaintiff admitted to his reported misdeeds. Upon learning of this and after plaintiff requested to not be asked to answer any additional questions without the presence of an attorney, Stephens placed plaintiff under arrest and charged him with employee theft.
Plaintiff subsequently filed suit against Walt Disney World and the Orange County Sheriff (“Beary”) on the basis of false imprisonment and several allegations of violations of his civil rights. Specifically, he alleged that the arrest made by Stephens had been made without probable cause and was in violation of plaintiff’s civil rights.
Beary subsequently moved for summary judgment on the claims filed against him. Beary’s motion was granted and the court then issued a show cause order demanding that plaintiff and his attorney demonstrate why they should not be deemed to be responsible for Beary’s attorney’s fees.
Issue: Whether the claim filed against Beary was in violation of Rule 11 of the Federal Rules of Civil Procedure and whether it would be proper to impose sanctions against plaintiff and his attorney.
Ruling: Yes and yes.
Rationale: Rule 11 of the FRCP imposes a duty upon attorneys and parties to refrain from filing or pursuing frivolous claims. Sanctions under this rule are proper when 1) a party files a pleading that has no reasonable factual foundation, 2) files a pleading that is based on a legal theory that has no reasonable chance of success and that cannot be advanced as a reasonable argument to change existing law, and 3) files a pleading in bad faith for improper purpose. If a violation is determined to have existed, Rule 11 allows courts to impose appropriate sanctions upon the attorneys, law firms, or parties that have violated the rule or are responsible for the violation. This can include all or part of the reasonable attorneys’ fees and other costs directly resulting from the violation.
In order to determine if a violation occurred, the court utilized a two-step mode of inquiry: 1) ehther the party’s claims are objectively frivolous, and 2) whether the person who signed the pleadings should have been aware that they were frivolous. After all, the purpose of Rule 11 is to deter frivolous lawsuits.
While the court was unable to determine whether plaintiff brought his suit against Beary in bad faith, they determined that it was objectively frivolous based in no small part on plaintiff’s own admission during a deposition that he did not feel as though Stephens had been doing anything other than his job and that he had not walked away feeling as though his civil rights had been violated. He stated that “[Stephens] arrested me because I confessed to something. Like I said, I knew he had a job to do, so apparently I believed he was doing his job as he thought he was supposed to.” The court also found that there was sufficient notice provided to plaintiff’s attorney by Beary’s about Beary’s attorneys’ intention to seek attorneys’ fees based on the fact that the claim against Beary had been frivolous.
The court ultimately concluded that the false arrest and conspiracy to violate civil rights claims brought by the plaintiff were foundationless and unreasonable. As such, the Court determined that even after it was patently obvious that plaintiff’s claims had no reasonable chance of success, plaintiff and his lawyer continued to pursue them further in strict violation of Rule 11. The court ordered plaintiff to pay attorneys’ fees to Beary.