Lambert v. Department of the Army

How later courts describe this case

• grant of Rule 11 motion not res judicata with respect to state claim of malicious prosecution
• denial of Rule 11 sanctions has no collateral estoppel effect in subsequent action for conspiracy, malicious prosecution, libel and intentional infliction of emotional distress
• denial of Rule 11 sanctions has no collateral estoppel effect in subsequent action for damages based on conspiracy, malicious prosecution, libel, and intentional infliction of emotional distress.
• “Legislators’ immunity is absolute, and extends to injunctive as well as to damages suits.”