ANN D. MONTGOMERY, District Judge.
This matter is before the undersigned United States District Judge for a ruling on Defendants' Motions for Sanctions [Docket Nos. 113, 120, 125, 133]. For the reasons stated below, the Motions for Sanctions are denied.
The Motions for Sanctions are based upon pro se plaintiff Gene Rechtzigel's ("Rechtzigel") filing of an Amended Complaint [Docket No. 26] alleging, among other things, that Defendants conspired to destroy his "liberty interests, real property, and constitutional rights" through their actions in multiple state court proceedings related to a property dispute. Am. Compl. ¶ 9. Defendants argue that sanctions against Rechtzigel are warranted under Rule 11 of the Federal Rules of Civil Procedure because the Amended Complaint was (1) frivolous in that it sought to relitigate facts and issues resolved in state court, and (2) filed in bad faith because it was intended solely to harass.
On April 8, 2016, the Court heard oral argument on the Motions for Sanctions at the same time it heard argument on Plaintiffs' Motion for Temporary Restraining Order [Docket No. 15] and Defendants' Motions to Dismiss [Docket Nos. 38, 52, 56, 61, 67, 72, 84, 85, 102, 107]. The Court orally denied Plaintiffs' Motion for a Temporary Restraining Order, granted Defendants' Motions to Dismiss, and stated that it would hold the Motions for Sanctions in abeyance for several months to determine whether Rechtzigel would continue to attempt to relitigate the state court proceedings in federal court.
Rule 11 of the Federal Rules of Civil Procedure authorizes sanctions against an attorney or party who files pleadings that have no legal or factual basis or that are filed for an improper purpose such as to harass or delay. Fed. R. Civ. P. 11(b), (c). A district court's decision on whether to impose sanctions is entitled to substantial deference "because it is in the best position to evaluate the circumstances surrounding an alleged violation and render an informed judgment."
The Motions for Sanctions are denied because this action is the first federal court case related to the long-running property dispute between Rechtzigel and Defendants. Further, Defendants' arguments for sanctions are based largely on Rechtzigel's exhaustive pursuit of this matter in state court. Moreover, the harm alleged by the Mohrman firm has been mitigated by its recovery of a substantial amount of legal fees from Rechtzigel pursuant to a judgment which Rechtzigel has paid and satisfied.
Although the Court declines to impose sanctions, Rechtzigel is warned that any future efforts by him to further pursue in federal court matters against Defendants that have already been resolved in state court will likely result in monetary sanctions as well as an anti-suit injunction enjoining him from filing any further federal cases against Defendants unless he is represented by licensed counsel and seeks leave of court.
Based upon all the files, records, and proceedings herein,