Hadges v. Yonkers Racing Corp.
United States Court of Appeals for the Second Circuit
48 F.3d 1320 (2d Cir. 1995)
Hadges (plaintiff), a racehorse driver, trainer, and owner, sued Yonkers Racing Corporation (YRC) (defendant) for banning him from its track after his license was reinstated. In seeking to reopen a prior dismissal, Hadges and his attorney William Kunstler stated Hadges had not worked in over four years and did not mention a related state-court suit; YRC showed Hadges had in fact worked briefly at another track and that a supporting document was misdated. The district court denied relief and imposed Rule 11 sanctions on both Hadges and Kunstler without first serving the required 21-day notice.
Whether an attorney making factual contentions in court is entitled to rely on the objectively reasonable representations of his client, and whether Rule 11 sanctions were properly imposed here.