Mary J. Baker v. St. Louis NH, LLC et al.

Summary

The United States District Court for the Eastern District of Missouri sanctioned attorney Johnathan Steele and The Steele Law Firm under Federal Rule of Civil Procedure 11 for filing a settlement declaration on behalf of Maria Loper without a reasonable factual inquiry into its contents or her competency. The court found that Steele’s concurrent representation of Mary Baker and Maria Loper created a conflict of interest and that Maria’s interests were inadequately protected until the court appointed a guardian ad litem. The court imposed a $12,250 monetary sanction payable to the wrongful-death beneficiaries and referred the matter to the Missouri Office of Disciplinary Counsel.

Holdings

1. Steele violated Federal Rule of Civil Procedure 11(b)(3) because he filed Maria's declaration while certifying factual assertions that he knew, or after reasonable investigation should have known, were false or wholly unsupported.
2. The court could impose sanctions because Steele received notice of the alleged Rule 11 violation and an opportunity to be heard through the show-cause order and his response.
3. A monetary sanction of $12,250 was appropriate, and the amount was ordered paid directly to the wrongful-death beneficiaries in proportion to their settlement shares rather than to the court.

Questions Presented

1. Whether Steele violated Federal Rule of Civil Procedure 11 by filing Maria Loper's declaration without a reasonable inquiry and without evidentiary support for its factual assertions.
2. Whether the court could impose sanctions after providing Steele notice and an opportunity to respond.
3. What sanctions were appropriate for the Rule 11 violation.

Disposition

other