Saltany v. Bush
D.C. Circuit
960 F.2d 1060 (D.C. Cir. 1992)
Fifty-five Libyan citizens (plaintiffs), including Saltany, sued President Reagan and others, including the United Kingdom, over the 1986 U.S. air strike on Libya; the district court dismissed the claims, and the court of appeals affirmed. Although the district court found plaintiffs' counsel must have known the suit had no chance of success, it declined to impose Rule 11 sanctions, citing the public value of keeping courts open to protest suits against the government; the United Kingdom appealed that decision and sought attorneys' fees, and the court of appeals reversed, finding sanctions were required, prompting this further appeal.
Whether the district court has discretion not to impose a sanction once it finds that a party has violated Rule 11.