Wayne Johnson v. Waddell & Reed, Inc.

Wayne Johnson, proceeding as a pro se litigant, was sanctioned $800 under Federal Rule of Civil Procedure 11 for persisting in the prosecution of a diversity suit that did not meet the $50,000 amount in controversy requirement of 28 U.S.C. § 1332. In imposing the sanctions, the district court did not comply with the then-newly amended requirements of Rule 11. A Rule 59(e) review of the sanctions was granted, and the district court ultimately let the sanctions order stand. This appeal concerns only the propriety of the imposition of sanctions, 1 and we reverse and vacate the sanctions order of…