Docket – October 19, 2018

4th U.S. Circuit Court of Appeals

Haynie v. United Airlines Inc. (U), 4th Cir. (per curiam) from EDVA at Alexandria (Brinkema).

The court vacated an award of $30,000 in defense attorneys’ fees, finding that although the district court listed the deficiencies in the plaintiff’s counsel’s representation and filings, its analysis didn’t permit adequate appellate review. Under Six v. Generations Fed. Credit Union, 891 F.3d 508 (4th Cir. 2018), the district court must show a causal link between wrongful conduct and an unreasonable and vexatious multiplication of proceedings and then connect the costs wrongfully incurred as a result of the sanctioned attorney’s conduct to the amount awarded to the moving party.

Vacated and remanded.

Categories: Daily Dockets

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