Christian v. Mattel, Inc.
United States Court of Appeals for the Ninth Circuit
286 F.3d 1118 (9th Cir. 2002)
Attorney Hicks filed a copyright infringement suit on behalf of Christian (plaintiff), alleging Mattel's (defendant) Barbie dolls infringed a copyrighted doll sculpture, when in fact Mattel's dolls had been created well before Christian's sculpture, making infringement factually impossible; the district court granted Mattel summary judgment and imposed Rule 11 sanctions against Hicks, citing both the baseless claim and Hicks's separately "boorish" discovery conduct and history of litigation misconduct.
Whether Rule 11 sanctions for filing a legally or factually baseless complaint may also rest on the attorney's separate misconduct during discovery, or must be based solely on the adequacy of the pre-filing investigation supporting the complaint itself.