Saltany v. Reagan
D.C. Circuit
886 F.2d 438 (D.C. Cir. 1989)
Relevant factsFree
Fifty-five Libyan citizens (plaintiffs), including Saltany, sued President Reagan and others, including the United Kingdom (defendants), 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 there was no possibility of success, it declined to impose Rule 11 sanctions, citing the value of keeping courts accessible to plaintiffs protesting government action; the United Kingdom appealed the sanctions ruling and separately sought attorneys' fees for defending the suit.
IssueFree
Whether the district court must impose a sanction on the offending party once it finds a Rule 11 violation.