Fletcher v. Doig

Plaintiffs filed a lawsuit asking the federal court declare that defendant, a well known artist, had created a painting that plaintiffs alleged was purchased from the artist; a contention that the artist denied. The district court ultimately entered judgment in favor of the defendant, finding that it was not painted by the defendant but by an individual with a similar name. The district court also granted the defendant’s motion for sanctions under FRCP 11 and plaintiff appealed the award of sanctions. The Seventh Circuit affirmed, finding that the district court did not abuse its discretion despite having denied defendant’s motion for summary judgment earlier in the case, noting that while there can be good faith to prosecute a claim at one stage of litigation, the claim can become frivolous pursuant to the discovery of additional information during litigation. (BRENNAN and KIRSCH, concurring)