Heimbaugh v. City & County of San Francisco
United States District Court for the Northern District of California
591 F.Supp. 1573 (N.D. Cal. 1984)
Police arrested Robert Heimbaugh (plaintiff) after he refused to sign a citation for playing softball in a section of Golden Gate Park where it was banned under the San Francisco Park Code. Heimbaugh, framing his softball-playing as "a statement about the right to democracy in recreation as opposed to elitism," sued the City and County of San Francisco and its officials (defendants) for violating his First, Fourth, and Fourteenth Amendment rights under 42 U.S.C. § 1983, seeking damages, a declaratory judgment, and an injunction. The defendants moved for summary judgment and for attorneys' fees as a Rule 11 sanction.
Whether sanctions under FRCP 11 are proper against a pro se litigant who files a frivolous lawsuit.