Muraoka v. American Osteopathic Ass'n

117 F.R.D. 616, 1987 U.S. Dist. LEXIS 10439, 45 Empl. Prac. Dec. (CCH) 37,705, 45 Fair Empl. Prac. Cas. (BNA) 419, 1987 WL 4284
CourtDistrict Court, N.D. Illinois
DecidedNovember 4, 1987
DocketNo. 86 C 6787
StatusPublished
Cited by1 cases

This text of 117 F.R.D. 616 (Muraoka v. American Osteopathic Ass'n) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Muraoka v. American Osteopathic Ass'n, 117 F.R.D. 616, 1987 U.S. Dist. LEXIS 10439, 45 Empl. Prac. Dec. (CCH) 37,705, 45 Fair Empl. Prac. Cas. (BNA) 419, 1987 WL 4284 (N.D. Ill. 1987).

Opinion

MEMORANDUM OPINION AND ORDER

ASPEN, District Judge:

Defendants, the American Osteopathic Association (“AOA”) and the National Os[617]*617teopathic Foundation (“NOF”), seek sanctions, pursuant to Fed.R.Civ.P. 11, for failure of plaintiff Charlene Muraoka’s attorneys Abraham Brustein and Jeffrey M. Marks of Dozoryst, Brustein, Neuman & Marks to conduct a “reasonable inquiry,” prior to filing this case, into the facts and law underlying Muraoka’s complaint. For the reasons discussed below, we grant the motion of AOA and NOF for sanctions under Fed.R.Civ.P. 11.

Factual Background

Plaintiff Muraoka filed the complaint and amended complaint in this case and alleged that defendants NOF and AOA violated § 504 of the Rehabilitation Act, 29 U.S.C. § 794 (1982).1 The complaint stated Muraoka was paid by the AOA and NOF, both recipients of federal funds, for duties which included the administration of a financial assistance program. The complaint contended Muraoka was forced to resign her position at the NOF solely because of defendants’ refusal to accommodate Muraoka’s handicap in violation of § 504. Despite these allegations, Muraoka was never paid by AOA funds, although AOA administered the NOF payroll accounts and therefore issued Muraoka’s payroll check. Additionally, neither AOA nor NOF administered a federal financial assistance program. In short, there was never any federal funding connection to Muraoka’s work, and, accordingly, she never had standing to sue under § 504. Six months into the case, Muraoka’s attorneys’ finally came to the same conclusion and moved to voluntarily dismiss the complaint. We dismissed the case with prejudice. Defendant then moved for sanctions under Fed.R.Civ.P. 11.2

Discussion

Section 504 of the Rehabilitation Act, 29 U.S.C. § 794 (1982), states a handicapped individual may not be subjected to discrimination under any program or activity receiving federal financial assistance. The Supreme Court has held this means that § 504 “by its terms, prohibits discrimination only by a ‘program or activity’ receiving Federal financial assistance ... (and) limits the ban on discrimination to the specific program that receives federal funds.” Consolidated Rail Corp. v. Darrone, 465 U.S. 624, 635-36, 104 S.Ct. 1248, 1255, 79 L.Ed.2d 568 (1984) (citations omitted) (emphasis added). See also Foss v. City of Chicago, 640 F.Supp. 1088, 1090 (N.D.Ill.1986) (the ban on discrimination under § 504 does not apply to all activities of every recipient of federal funds; the discrimination must relate to the specific program or activity that receives federal funds); adopted, 817 F.2d 34 (7th Cir.1987).

The purpose of § 504 is. not to provide a general prohibition on discrimination against the handicapped by recipients of federal funds. Simpson v. Reynolds Metals Co., 629 F.2d 1226, 1232 (7th Cir.1980). Rather, the discrimination must come in the “operation of the program or manifest itself in a handicapped individual’s exclusion from the program or a diminution of the benefits he would otherwise receive from the program.” Id.

In order to have standing to sue under § 504, Muraoka needed to show that the program or activity she worked on at the NOF was funded by federal financial assistance. In her amended complaint, Muraoka alleged upon information and belief that the defendants were recipients of financial assistance from the United States. In her deposition, she stated she had rea[618]*618son to believe the AOA and the federal funds it received were involved in the loan program she administered for both the AOA and NOF. This belief was based in part on a conversation Muraoka had with her former supervisor Mr. Lee Stein and on the assumption that the AOA, which processed her paychecks, paid her salary for administering the loan program. After six months of discovery, however, Muraoka’s attorneys learned that Muraoka in fact did not have standing to sue under § 504 and requested a voluntary dismissal of this action. The case was dismissed with prejudice and defendants requested sanctions under Rule 11.

The question before the Court is whether Muraoka’s attorneys conducted an investigation that was “reasonable under the circumstances” and whether they could have determined, prior to filing the complaint, that Muraoka did not meet the program-specific requirement of § 504. The test under Rule 11 for sanctions is “objective.” Thornton v. Wahl, 787 F.2d 1151, 1154 (7th Cir.), cert. denied, — U.S. —, 107 S.Ct. 181, 93 L.Ed.2d 116 (1986). “An attorney risks sanctions for-failing to make a ‘reasonable inquiry’ into both the factual and legal basis for the claim he asserts.” Brown v. National Board of Medical Examiners, 800 F.2d 168, 172 (7th Cir.1986). The Seventh Circuit determined:

The principal function of the 1983 amendment to Rule 11 was to add the requirement of adequate investigation before filing a complaint. It is not permissible to file a suit and use discovery as the sole means of finding out whether you have a case.... Rule 11 requires independent inquiry. The amount of investigation required by Rule 11 depends on both the time available to investigate and on the probability that more investigation will turn up important evidence.... Only a “reasonable” inquiry is necessary.

Szabo Food Service, Inc. v. Canteen Corp., 823 F.2d 1073, 1083 (7th Cir.1987) (citations omitted).

Rule 11 requires that counsel not rely solely upon the allegations made by the client, but that they also conduct an independent inquiry into the facts. O’Rourke v. City of Norman, 640 F.Supp. 1451, 1469 (W.D.Okla.1986). An attorney must investigate the relevant facts and the requirements of the law to determine whether the facts support a recognized entitlement to relief. In re TCI Ltd., 769 F.2d 441, 446 (7th Cir.1985). This, of course, is tempered by the requirement that the investigation be reasonable. Thus, in a situation where a client comes to an attorney only weeks or days before a statute of limitations begins to run, then much less of a factual inquiry would be reasonable. This is not, however, the case here.

When the defendants deposed Muraoka’s former supervisor at NOF, Mr.

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117 F.R.D. 616, 1987 U.S. Dist. LEXIS 10439, 45 Empl. Prac. Dec. (CCH) 37,705, 45 Fair Empl. Prac. Cas. (BNA) 419, 1987 WL 4284, Counsel Stack Legal Research, https://law.counselstack.com/opinion/muraoka-v-american-osteopathic-assn-ilnd-1987.