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Isaacs v. Quality Auto Center, Inc.

United States District Court, Third Circuit

August 2, 2013

RICHARD ISAACS, Plaintiff,
v.
QUALITY AUTO CENTER, INC., Defendants.

OPINION AND ORDER DENYING DEFENDANTS' MOTION FOR SANCTIONS [D.E. 34]

STEVE MANNION, District Judge.

I. INTRODUCTION

Pending before the Court is defendants Quality Auto Center, Inc. and Kamlesh C. Shah's ("Defendants") motion for sanctions against plaintiff Richard Isaacs ("Isaacs" or "Plaintiff") for attorney's fees and costs. (D.E. 34). Plaintiff opposes the motion. (D.E. 36). The Court has considered the parties' submissions pursuant to Federal Rule of Civil Procedure 78(b), and for the reasons set forth below denies Defendants' motion.

II. BACKGROUND

This matter was filed on August 24, 2011. (D.E. 1, Complaint). Plaintiff alleged violations of the State and Federal Wage and Hour Laws on behalf of himself and others alleged to be similarly situated. Defendants answered the Complaint. (D.E.s 3, Answer and 5, Amended Answer).

After several discovery disputes, defendants moved for sanctions, including dismissal, attorneys' fees, and costs imposed against plaintiff Isaacs for failure to comply with orders of the Court. (D.E. 18, Motion for Sanctions). Plaintiff opposed. (D.E. 19). The parties subsequently agreed to a consent order that dismissed the class action claims with prejudice and preserved defendants' rights to seek fees and costs. (D.E. 33, Consent Order). Defendant then filed this motion. (D.E. 34).

III. DISCUSSION

"[D]istrict courts have broad authority to preserve and protect their essential functions." Republic of Philippines v. Westinghous Electric Corp., 43 F.3d 65, 73 (3d Cir. 1994). The Federal Rules of Civil Procedure provide several tools that allow district courts to sanction parties or attorneys "who fail to meet minimum standards of conduct in many different contexts." Id . (citing e.g. Fed.R.Civ.P 11 (groundless pleadings and other papers); 16(f)(failing to abide by pre-trial orders); 26(g), 30(g), 37(d), and 37(g)(discovery abuses), 41(b) (involuntary dismissal for failure to prosecute, failure to obey court order or follow rules), 45(f)(disobeying subpoena), 56(g)(providing affidavit in bad faith on summary judgment motion or for delay).

Federal Rule of Civil Procedure 11 was designed to deter pleadings that are "frivolous, legally unreasonable, or without factual foundation...." Napier v. Thirty or More Unidentified Federal Agents, 855 F.2d 1080, 1090-91 (3d Cir. 1988) (internal quotations omitted). Under Rule 11(c), "the court may impose an appropriate sanction on any attorney, law firm, or party that violate[s] [r]ule [11(b)] or is responsible for the violation." Rule 11(b) states:

By presenting to the court a pleading, written motion, or other paper-whether by signing, filing, submitting, or later advocating it-an attorney or unrepresented party certifies that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances:

(1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;
(2) the claims, defenses, and other legal contentions are warranted by existing law or by a non-frivolous argument for extending, modifying, or reversing existing law or for establishing new law;
(3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and
(4) the denials of factual contentions are warranted on the evidence, or if specifically so identified, are reasonably based on ...

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