Hays v. Sony Corp. of America
United States Court of Appeals for the Seventh Circuit
847 F.2d 412 (7th Cir. 1988)
Stephanie Hays and Gail MacDonald (plaintiffs), public school teachers, wrote an uncopyrighted instructional manual for word processors, which the school later gave to Sony Corporation of America (Sony) (defendant) to adapt for new machines the school had purchased; Sony updated it without compensation and did not sell or distribute it further. After the plaintiffs registered a copyright on the manual, their attorney, Emmanuel Guyon, sued Sony for common-law and statutory copyright infringement, seeking damages, an accounting of profits, punitive damages, and other relief. The district court dismissed the complaint for failure to state a claim and, on Sony's motion, sanctioned Guyon personally under FRCP Rule 11, ordering him to pay a substantial share of Sony's attorney's fees. Guyon appealed the sanctions.
Whether an attorney who files claims without conducting a reasonable inquiry into their legal and factual basis may be personally sanctioned under Rule 11 of the Federal Rules of Civil Procedure.