City of New York v. Eastway Construction Corp.

showing of subjective bad faith not required to trigger Rule 11 sanctions | death penalty statute neither vague, overbroad, imposed in a discriminatory manner, nor involves subjective discretion | death penalty statute neither vague, overbroad, imposed in a discriminatory manner, nor involves subjective discretion | wherein the Court, addressing a claim made pursuant to Batson v. Kentucky , 476 U.S. 79 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986 | wherein the Court, addressing a claim made pursuant to Batson v. Kentucky, 476 U.S. 79, 106 S.Ct. 1712, 90 L.Ed.2d 69 (1986 | sanctions can be imposed for filings made for an “improper purpose” even where the attorney conducted a reasonable investigation | Rule 11 is violated when it is "patently clear that a claim has absolutely no chance of success under the existing precedents" | all ambiguities and inferences should be resolved in favor of the party defending a summary judgment motion | “Even a single act of invidious discrimination may form the basis for an equal protection violation.” | "The defendant cannot successfully argue that error is plain in the record when there is no indication in the record that the act upon which error is predicated ever occurred." | theory not presented to trial court and first raised on appeal not properly before appellate court. | theory not presented to trial court and first raised on appeal not properly before appellate court. | change in death penalty sentencing scheme not ex post facto because it affected neither the crime, punishment prescribed, nor degree of proof necessary to establish guilt | although district court relied on affidavits in granting summary judgment, appellate court stated that it would have been “equally proper to dismiss the civil rights count for failure to state a claim” | attorney’s fee award under Rule 11 may be limited to amount thought reasonable to serve the sanctioning purpose of the rule as long as it does not fall below the bottom range of discretion | the full amount of legal fees "need not be routinely awarded." | Sanctions are merited when “it is patently clear that a claim has absolutely no chance of success under the existing precedents, and where no reasonable argument can be advanced to extend, modify or reverse the law as it stands.” | the full amount of legal fees “need not be routinely awarded.” | good faith no longer provides a “safe harbor” from sanctions | prior conviction of a violent felony | prior conviction of a violent felony