Jones v. National Railroad Passenger Corporation

CourtDistrict Court, N.D. California
DecidedSeptember 27, 2024
Docket3:15-cv-02726
StatusUnknown

This text of Jones v. National Railroad Passenger Corporation (Jones v. National Railroad Passenger Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. National Railroad Passenger Corporation, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 AMANDA JONES, Case No. 15-cv-02726-TSH

8 Plaintiff, ORDER RE PLAINTIFF’S MOTION 9 v. FOR SANCTIONS AND COURT’S ORDER TO SHOW CAUSE 10 NATIONAL RAILROAD PASSENGER CORPORATION, et al., Re: Dkt. 456, 467 11 Defendants. 12 13 I. INTRODUCTION 14 Plaintiff Amanda Jones moves for sanctions in the amount of $75,594.67 against 15 Defendant Santa Cruz Metropolitan Transit District (“SCMTD”) and/or its counsel. ECF Nos. 16 456, 464, 465. SCMTD filed an Opposition (ECF No. 469) and Plaintiff filed a Reply (ECF No. 17 472). In addition, the Court ordered SCMTD and its counsel to show cause why they should not 18 be sanctioned. ECF No. 467. They responded at ECF No. 471. Having considered the parties’ 19 positions, relevant legal authority, and the record in this case, the Court GRANTS Plaintiff’s 20 motion in part and SUSTAINS the order to show cause in part, and orders Robert G. Howie, 21 Counsel for SCMTD, to pay monetary sanctions in amount of $46,363.29 for the following 22 reasons.1 23 II. BACKGROUND 24 November 29, 2023, was the first day of an anticipated two-week trial in the above- 25 captioned matter. The scheduled trial was a retrial, following a trial in March 2023 in which the 26 jury was unable to reach a verdict. Prior to trial, both Plaintiff and Defendant confirmed they were 27 1 not planning to call any witnesses who did not testify in the previous trial. Pretrial Conf. Tr. at 2 12–13, ECF No. 461. On the first day of trial, following voir dire by the Court and Plaintiff’s 3 counsel, counsel for SCMTD, Robert G. Howie, began voir dire for the defense. Before asking 4 the prospective jurors any questions, Howie informed the entire pool of prospective jurors that the 5 Plaintiff (1) had multiple sclerosis (MS), and (2) was “confined to a wheelchair for reasons that 6 have nothing to do with” the lawsuit. Trial Tr. at 12–13, ECF No. 460. 7 In its oral ruling granting Plaintiff’s motion for a mistrial, the Court stated the following:

8 The major issue in dispute in this case is causation, and Mr. Howie’s statement in front of the prospective jurors that the plaintiff has MS 9 goes directly to the issue of causation in a way that is prejudicial to Plaintiff’s case. In the previous trial I do not recall there was any 10 mention of MS, and both sides have told me that they were planning to call the same witnesses to testify at this trial as in the previous trial, 11 and so I have no basis to think that evidence regarding MS would be admissible. I do think it is massively prejudicial the way that it was 12 told to the prospective jurors, and, again, it goes directly to the core issue in this case, which is causation. Accordingly, the plaintiff’s 13 motion for a mistrial is granted. 14 Id. at 17. 15 In ECF No. 456, Plaintiff moved for sanctions for attorneys’ fees and costs incurred 16 because of the mistrial. In ECF No. 459, the Court observed that “[t]he responding parties are 17 entitled to notice and an opportunity to respond to the amount of the requested sanctions.” 18 Accordingly, the Court ordered Plaintiff to file by December 15, 2023 one or more declarations 19 specifying in detail the amount of the sanctions and what each cost item is for. Those declarations 20 are filed at ECF Nos. 464 and 465. The Court set the responding parties’ deadline to respond to 21 the motion for sanctions as December 29, 2023, and set January 5, 2024 as the deadline for 22 Plaintiff’s optional reply. ECF No. 459. The Court subsequently ordered supplemental briefing 23 concerning Plaintiff’s request for sanctions. ECF No. 478. The Court set a deadline of May 6, 24 2024 for Plaintiff’s supplemental brief, a deadline of May 13, 2024 for Defendants’ optional 25 response, and a deadline of May 20, 2024 for Plaintiff’s optional reply. Id. Plaintiff filed a 26 supplemental brief on May 6. ECF No. 480. Defendants did not file an optional response, and 27 Plaintiff did not file an optional reply. 1 the Court should not sanction them for the Court-incurred expenses associated with the 2 empanelment of the prospective jurors, as well for the costs incurred by Plaintiff and Plaintiff’s 3 counsel. In other words, Plaintiff’s fees and costs associated with the mistrial are the subject of 4 both Plaintiff’s motion and the Court’s OSC, whereas the Court’s costs related to the jury 5 empanelment are embraced only by the OSC. 6 III. DISCUSSION 7 Plaintiff moves for sanctions under 28 U.S.C. § 1927, the Court’s inherent power, Civil 8 Local Rules 1-4 and 11-4(a)(4), and California Rule of Professional Conduct 8.4. The Court’s 9 OSC invoked only section 1927. 10 A. Imposition of Sanctions Under 28 U.S.C. § 1927 11 1. Legal Standard 12 Pursuant to 28 U.S.C. § 1927, “[a]ny attorney or other person admitted to conduct cases in 13 any court of the United States or any Territory thereof who so multiplies the proceedings in any 14 case unreasonably and vexatiously may be required by the court to satisfy personally the excess 15 costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” “[A] finding 16 that the attorney[] recklessly raised a frivolous argument which resulted in the multiplication of the 17 proceedings’ justifies § 1927 sanctions.” Caputo v. Tungsten Heavy Powder, Inc., 96 F.4th 1111, 18 1155 (9th Cir. 2024) (quoting In re Girardi, 611 F.3d 1027, 1061 (9th Cir. 2010)) (emphasis in 19 original). Sanctions under § 1927 may only be imposed upon individual attorneys, rather than 20 against the client or law firm. Kaass Law Firm v. Wells Fargo Bank, N.A., 799 F.3d 1290, 1293– 21 94 (9th Cir. 2015). 22 2. Discussion 23 In his opposition, Howie contends that sanctions should only be imposed upon a showing 24 of bad faith or reckless conduct coupled with an improper purpose. Opp’n at 7, ECF No. 469. 25 The Court recognizes that within the last decade, courts in this circuit have not been entirely 26 consistent about whether a finding of bad faith is required to impose sanctions under 28 U.S.C. § 27 1927. However, in Caputo, the Ninth Circuit’s most recent published decision on the matter, the 1 argument which resulted in the multiplication of the proceedings’ justifies § 1927 sanctions.” 96 2 F.4th at 1155 (quoting In re Girardi, 611 F.3d 1027, 1061 (9th Cir. 2010)) (emphasis in original); 3 see also In re Keegan Mgmt. Co., Secs. Litig., 78 F.3d 431, 436 (9th Cir. 1996) (“Bad faith is 4 present when an attorney knowingly or recklessly raises a frivolous argument.”) (cleaned up). 5 The Court finds Howie’s statements to the prospective jurors constituted the raising of a 6 frivolous argument. Howie did not indicate that any witness would be called to testify that MS 7 caused the injuries Plaintiff alleges, nor did he indicate that any such evidence would be 8 admitted—or even admissible—at trial. See Trial Tr. at 16-17. Howie did state that Dr. Conte 9 determined that Plaintiff has MS, and that her MS was not caused by the accident. But neither 10 side was planning to call Dr. Conte as a witness at trial, which Howie acknowledged. Id.

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Jones v. National Railroad Passenger Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-national-railroad-passenger-corporation-cand-2024.