Houston v. Southwest Airlines

Filing 42

MEMORANDUM ORDER: Before the Court is Defendant Southwest Airlines' (Southwest) Motion for Sanctions (ECF No. 40 ). Accordingly, Southwest's Motion for Sanctions is DENIED. By denying Southwest's sanctions motion, the Court does not f ind that Southwest's counsel acted inappropriately or incorrectly represented that Houston failed to answer Southwest's discovery requests. Rather, the Court finds that counsel acted in good faith and with appropriate candor to Houston and to the Court. (Ordered by Magistrate Judge Rebecca Rutherford on 2/18/2020) (ctf)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
CHANDLER HOUSTON,
Plaintiff,
v.

Case No. 3:17-cv-02610-N-BT

SOUTHWEST AIRLINES,
Defendant.
MEMORANDUM ORDER
Before the Court is Defendant Southwest Airlines’ (Southwest) Motion for
Sanctions (ECF No. 40). Southwest served interrogatories and requests for
admission on Plaintiff Chandler Houston, and it maintains that Houston did not
respond. In her summary judgment response, however, Houston asserts that she
responded to Southwest’s interrogatories and requests for admission via email on
April 20, 2019, and even followed up with counsel on May 1, 2019, to confirm
Southwest’s receipt of her answers. Resp. Mot. Summ. J. 5 (ECF No. 34).
Southwest objects that Houston’s statements are “materially false” and contends
that she made them for the improper purpose of avoiding summary judgment.
Southwest seeks sanctions under Fed. R. Civ. P. 11 and the Court’s inherent power
in the form of an order: (1) striking Houston’s summary judgment response
without leave to amend; (2) granting Southwest’s Motion for Summary Judgment;
and (3) requiring that Houston pay Southwest $1,015.00 in attorney’s fees. Mot.
Sanctions 4. Houston did not respond to Southwest’s Motion for Sanctions.
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Federal Rule of Civil Procedure 11 authorizes a court to impose sanctions on
a party or an attorney who files a pleading for an improper purpose, such as to
harass the opposing party, delay the proceedings, or increase the cost of litigation.
Fed. R. Civ. P. 11(b), (c). “The central purpose of Rule 11 is to deter baseless filings
in district court and thus . . . streamline the administration and procedure of the
federal courts,” (Cooter & Gell v. Hartmax Corp., 496 U.S. 384, 393 (1990)), and
to “spare innocent parties and overburdened courts from the filing of frivolous
lawsuits,” (Cappa Fund III, L.L.C. v. Actherm Holding, A.S., 2011 WL 817384, at
*2 (N.D. Tex. Feb. 21, 2011), rec. adopted, 2011 WL 816861 (N.D. Tex. Mar. 9,
2011)). “However, [Rule 11] sanctions are normally reserved for the rare and
exceptional case where the action is clearly frivolous, legally unreasonable, or
without legal foundation or brought for an improper purpose. It is an extraordinary
remedy, one to be exercised with extreme caution.” Laughlin v. Perot, 1997 WL
135676, at *8 (N.D. Tex. Mar. 12, 1997) (internal footnotes and quotations omitted,
emphasis in the original). Among the factors that a court considers in determining
whether a person has complied with Rule 11 is his or her pro se status. Thomas v.
Capital Sec. Servs. Inc., 836 F.2d 866, 875 (5th Cir. 1988). Although the Rule 11
standard applies equally to pro se parties as it does to attorneys, a court has
“sufficient discretion to take account of the special circumstances that often arise
in pro se situations.” Fed. R. Civ. P. 11 advisory committee’s notes.
Courts also have inherent authority to impose sanctions on attorneys when
they find that an attorney has “acted in bad faith, vexatiously, wantonly, or for
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oppressive reasons.” Chambers v. NASCO, Inc., 501 U.S. 32, 45 (1991). Courts
“exercise caution” in invoking their inherent power and should “ordinarily” rely on
a rule or statute rather than their inherent power. Id. at 50. Nonetheless, in order
to award sanctions under its inherent powers, a court “must make a specific finding
of bad faith.” In re Goode, 821 F.3d 553, 559 (5th Cir. 2016). Bad faith conduct
includes conduct that is motivated by improper purposes such as harassment or
delay. Coghlan v. Starkey, 852 F.2d 806, 814 (5th Cir. 1988) (per curiam). Thus,
bad faith conduct resembles conduct that would violate Rule 11(b)(1). Chambers,
501 U.S. at 46 n.10.
Here, the Court declines to impose sanctions under either Rule 11 or its
inherent powers. The record in this case does not clearly establish that Houston’s
assertions that she responded to Southwest’s discovery requests were made for an
improper purpose. Indeed, there is no evidence in the record regarding Houston’s
intent. She may have honestly, but mistakenly, believed she properly answered
Southwest’s discovery requests. Sanctions under the Court’s inherent authority are
inappropriate for the same reason. Accordingly, Southwest’s Motion for Sanctions
is DENIED.
By denying Southwest’s sanctions motion, the Court does not find that
Southwest’s counsel acted inappropriately or incorrectly represented that Houston
failed to answer Southwest’s discovery requests. Rather, the Court finds that
counsel acted in good faith and with appropriate candor to Houston and to the
Court.
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SO ORDERED.
February 18, 2020.
____________________________
REBECCA RUTHERFORD
UNITED STATES MAGISTRATE JUDGE

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