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Chaplin v. Du Pont Advance Fiber Sys. - 124 F. App'x 771 (4th Cir. 2005)


Fed. R. Civ. P. 11(b)(2) allows the district court to award sanctions for unwarranted legal contentions. Rule 11(b)(2) requires an attorney to certify that the claims are warranted by existing law or by a nonfrivolous argument for the extension, modification, or reversal of existing law or the establishment of new law.


Each employee professed to be a Caucasian, a Christian, and a Confederate Southern American. The employees alleged that the employer's policy banning the display of the Confederate battle flag violated Title VII. The United States District Court for the Eastern District of Virginia, at Richmond, dismissed the claims, sanctioned the employees' attorney pursuant to Fed. R. Civ. P. 11(b)(3), and awarded attorney's fees under 42 U.S.C.S. § 2000e-5(k). The attorney and the employees appealed.


Did the district court abuse its discretion in imposing sanctions and awarding fees?




The appellate court determined that the district court did not abuse its discretion in imposing sanctions and awarding fees. The religious discrimination claim lacked any factual basis because no evidence existed in the record to suggest that the employees requested an accommodation of their religious beliefs prior to the filing of their Equal Employment Opportunity Commission charge. Although the employees could bring causes of action for both race discrimination and national origin discrimination, the race discrimination claim was unwarranted because the employees failed to aver that they had suffered any adverse employment action. Regarding the fee award, it was unreasonable for the employees to bring the action based upon a policy that caused them nothing more than aggravation.

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