Frantz v. U.S. Powerlifting Federation
United States Court of Appeals for the Seventh Circuit
836 F.2d 1063 (7th Cir. 1987)
Frantz and another weightlifter (plaintiffs) sued the IPF, USPF, and USPF's president Cotter (defendants), alleging antitrust violations after being disqualified from IPF events for previously competing in a rival federation's events. After a default judgment against IPF and dismissal of claims against Cotter and USPF on 12(b)(6) motions, an amended complaint against USPF alone was also dismissed. The district court awarded Cotter attorneys' fees under Rule 11, finding the claim against him frivolous, but denied USPF fees, finding the claims against it colorable — then the judge, shocked that Cotter's fee request itself totaled $44,700 (with $40,400 spent just preparing the fee request), vacated Cotter's award. Both Cotter and USPF appealed.
Whether a party must perform legal research before filing a complaint to ensure the claim is not frivolous, with each individual claim required to be colorable in its own right.