Aldridge alleged in his complaint that while he was on the way to work he was assaulted by police officers and beaten. However, there was video evidence showing that no such thing actually happened. Instead of dropping the lawsuit, Aldridge resisted summary judgment and put the Defendants to significant expense. The defendants moved for sanctions and the district court awarded $12,000 against Aldridge’s counsel, with $10,000 to be paid to the defendants and $2,000 to be paid to the court.
The Sixth Circuit affirmed the grant of sanctions with this explanation:
Finally, the district court’s imposition of Rule 11 sanctions against Aldridge’s counsel was proper, for the reasons already well and carefully stated by that court. As the court stated:
By the time the motion for summary judgment was filed, no reasonable person would (1) believe that [Aldridge] was on his way to work, (2) believe that the 9-1[-1] audio did not describe [Aldridge], (3) disbelieve the third-party witnesses who testified that they did not see [Aldridge] beaten, or (4) believe that [Aldridge] was beaten after having seen the video of him being handcuffed and then sitting in the rear of the police vehicle.On appeal, Aldridge contends that sanctions should be granted only to deter rather than to compensate. But indeed the court made clear in its ruling that the principal objective of the sanctions was “to deter the abuse of the legal process,” and specifically capped the defendants’ recovery at $10,000, even though defense counsel billed more to defend this suit. Nor has Aldridge pointed to anything in the record or any case that might suggest that the court’s award was out of step with Rule 11 or its deterrent purpose. Furthermore, despite Aldridge’s claim that allowing the sanctions to stand will chill future civil-rights litigation, just as serious a concern is the corrosive effect that frivolous suits like his have on the prosecution of genuine civil-rights cases. For, as already explained, once the backseat video came to light, it became patently clear that the allegations set forth in Aldridge’s complaint could not be true as stated. In light of that fact, Aldridge’s counsel had a duty to reconsider their case pursuant to Rule 11. See Runfola & Assocs. v. Spectrum Reporting II, Inc., 88 F.3d 368, 373-74 (6th Cir. 1996). For these reasons and others already given by the district court, the imposition of sanctions was not an abuse of discretion.
Source: Aldridge v. City of Warren, Court of Appeals, 6th Circuit 2017 – Google Scholar
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