Young v. City of Providence ex rel. Napolitano

Young's (plaintiff) attorneys, litigating a section 1983 wrongful-death suit against the City of Providence (defendant), agreed before trial to a stipulation about an inaccurate diagram, then mid-trial sought release from that stipulation via a memorandum drafted by a young associate. The trial judge read the memorandum as implying she had coerced Young into accepting the stipulation, found this a misrepresentation, and, despite the attorneys' apology and explanation, stripped two out-of-state attorneys of their pro hac vice status and sanctioned them under Rule 11 (without sanctioning local counsel, whom she also found in violation).

Whether bad faith must be shown when the court itself initiates a Rule 11 inquiry.