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Chaplin v. Du Pont Advance Fiber Sys. - 303 F. Supp. 2d 766


Whether a civil complaint satisfies the requirements of Rule 11 depends upon how it measures up against three criteria: (1) the complaint must be filed for a proper purpose; (2) each count of the complaint must have a sufficient basis in law; and (3) each of the claims must have a sufficient basis in fact.


Plaintiff employees sued defendant employer claiming the employer's ban on the display of the Confederate flag discriminated against them based upon their national origin (Southern Confederate Americans), their religion, and their race. The claims were dismissed. Before the court was the employer's motion for sanctions pursuant to Fed. R. Civ. P. 11 and its' motion for attorneys' fees and expenses pursuant to 42 U.S.C.S. § 2000e-5(k).


Did the plaintiffs’ civil complaint satisfy the requirements of Fed. R. Civ. P. 11 (Rule 11)?




The court vacated and reversed its previous ruling on these matters. The court held that: (1) plaintiffs' attorney's purpose in filing the lawsuit was not to harass the employer but, rather, to create or expand Title VII jurisprudence; (2) without authoritative case law either way, the claim was not unwarranted; (3) however, there was no factual foundation for the religious and racial discrimination claims since the employees had not requested a religious accommodation and their averred class of Southern Confederate Americans was multiracial. Whether those counts were the product of bad faith or just poor judgment, it was the opinion of the court that each was so devoid of merit as to warrant Rule 11 sanctions. The court held that its public reprimand of the employees' attorney was a sufficient deterrent or violating U.S. Dist. Ct., E.D. Va., R. 83.1(F) by filing pleadings on behalf of his clients and labeling them pro se. The employer had sought $59,989.49 for attorney's fees of which the court found $42,446 to be reasonable and then further adjusted the award, primarily due to the relative financial positions of the litigants, to $26,100 in attorneys' fees and costs of $1,450, for a total of $27,550. The court further sanctioned counsel for plaintiffs in the amount of $10,000.

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