Question
Read the following summary of the Sprewell v. Golden State Warriors case.Using the Utah Rules of Professional Conduct, explain whether or not Sprewell's attorneys violated
Read the following summary of the Sprewell v. Golden State Warriors case.Using the Utah Rules of Professional Conduct, explain whether or not Sprewell's attorneys violated any rules.
Imposition of sanctions against Sprewell's attorneys for filing a frivolous lawsuit.
Facts
Sprewell joined the NBA in 1992 as a guard for the Golden State Warriors. During Sprewell's tenure with the Warriors, he played under four different head coaches, the last of whom was P.J. Carlesimo. Sprewell's star-crossed relationship with
Carlesimo, while initially amicable upon its inception in June of 1997, quickly deteriorated over the ensuing six months to the point that both Sprewell and the Warriors openly entertained the possibility of trading Sprewell to another team. Tensions between Sprewell and Carlesimo climaxed during a closed-door practice on December 1, 1997, during which Carlesimo told Sprewell to pass the ball to a teammate for a quick shot. Despite Sprewell's contention that he passed the ball "admirably, as one would expect of an All-Star," Carlesimo rebuked Sprewell for not putting more speed on his pass. When Carlesimo subsequently repeated his criticism, Sprewell slammed the ball down and directed several expletives at Carlesimo. Carlesimo responded with a similar showing of sophistication. Sprewell immediately either walked or lunged at Carlesimo and wrapped his hands around Carlesimo's neck. With his arms fully extended, Sprewell moved Carlesimo backwards, saying "I will kill you." Carlesimo offered no resistance. Sprewell grasped Carlesimo's neck for approximately seven to ten seconds -- the time it took for other players and coaches to restrain Sprewell. Sprewell then left the practice floor, saying "trade me, get me out of here, I will kill you," to which Carlesimo countered, "I am here." After showering and changing, Sprewell returned to the practice facility to again confront Carlesimo. Despite the efforts of two assistant coaches to restrain him, Sprewell was able to approach Carlesimo and throw an overhand punch that grazed Carlesimo's right cheek. Sprewell landed a subsequent blow to Carlesimo's shoulder, but it is uncertain whether it was intentional or the product of Sprewell's attempt to free himself from those restraining him. As Sprewell left the facility, he again told Carlesimo, "I will kill you." That evening the Warriors suspended Sprewell for a minimum of ten games and expressly reserved its right to terminate Sprewell's contract. Two days later, the Warriors exercised that right and ended Sprewell's reign as a Warrior. The NBA subsequently issued its own one-year suspension of Sprewell after conducting an independent investigation of the matter.
Sanctions
The district court did not abuse its discretion in imposing sanctions against Sprewell's attorneys. Orders imposing Rule 11 sanctions are reviewed for an abuse of discretion. Reversal of the district court is possible only when we are "convinced firmly that the reviewed decision lies beyond the pale of reasonable justification under the circumstances." Rule 11 provides for the imposition of sanctions when a filing is frivolous, legally unreasonable, or without factual foundation, or is brought for an improper purpose. Frivolous filings are "those that are both baseless and made without a reasonable and competent inquiry."
Sprewell's attorneys correctly point out that we have traditionally exercised a high level of restraint in imposing sanctions against civil rights plaintiffs, doing so only in exceptional cases. Sprewell's submission of an amended complaint that failed to ameliorate the weaknesses inherent in his original complaint makes this an "exceptional case."
After providing Sprewell with a comprehensive explanation as to why the court deemed Sprewell's original complaint to be without merit, the district court urged Sprewell and his counsel to seriously consider "not amending at all, and simply dropping the matter at this point." The district court went on to state that it would allow Sprewell to amend his complaint only if each attorney representing Sprewell personally signed any amended pleading in accordance with Rule 11. Sprewell's attorneys, however, disregarded the warnings of the district court and filed another baseless complaint mirroring the original.
Therefore, even though we have traditionally exercised a heightened level of restraint in imposing sanctions against civil rights plaintiffs, here, the deferential standard of review controls. We cannot say that the district court abused its broad discretion.
Conclusion
For the reasons outlined above, we affirm the district court's dismissal of Sprewell's claims against the NBA and the Warriors, and affirm the district court's imposition of sanctions.
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