Heimbaugh v. City & County of San Francisco

Robert Heimbaugh (plaintiff) was arrested after refusing to sign a citation for playing softball where it was prohibited under the San Francisco Park Code. He sued the City and its officials (defendants) under 42 U.S.C. section 1983, claiming First, Fourth, and Fourteenth Amendment violations and framing his softball playing as 'a statement about the right to democracy in recreation.' The defendants moved for summary judgment and Rule 11 sanctions.

Whether Rule 11 sanctions are proper against a pro se litigant who files a frivolous lawsuit.