## Facts

- James Bridges sued his former employer, Diesel Service, Inc. (Diesel), in federal court, alleging that Diesel terminated him in violation of the Americans with Disabilities Act (ADA).
- Bridges filed his ADA lawsuit before filing any charge with the Equal Employment Opportunity Commission (EEOC), even though ADA employment claims generally require the plaintiff to first pursue administrative remedies through the EEOC process.
- After the filing error was identified, Bridges’s attorney took steps to correct it by filing an EEOC charge and asking the federal court to pause the case while the administrative process proceeded.
- The district court dismissed Bridges’s ADA complaint without prejudice because he failed to exhaust administrative remedies before filing suit.
- Diesel then moved for sanctions under Federal Rule of Civil Procedure 11 against Bridges’s attorney, arguing that filing an ADA action without first confirming the EEOC exhaustion requirement showed an unreasonable prefiling legal inquiry.

## Issues

1. Whether filing an ADA employment-discrimination complaint before exhausting EEOC administrative remedies, by itself, warrants Rule 11 sanctions against plaintiff’s counsel.
2. Whether a correctable failure to satisfy an administrative prerequisite supports monetary sanctions when there is no showing that the claim was frivolous or filed for an improper purpose.

## Decision

- The court denied Diesel’s motion for Rule 11 sanctions against Bridges’s attorney.
- The court’s earlier dismissal without prejudice for failure to exhaust administrative remedies remained in effect.

## Legal Principles

- Rule 11 requires an attorney, before filing a pleading, to conduct a reasonable inquiry into whether the filing is legally and factually supportable.
- Rule 11 is aimed at deterring improper litigation conduct; it is not meant to operate as a routine fee-shifting mechanism after a dismissal.
- Monetary sanctions are generally reserved for exceptional situations, such as filings that are patently meritless, legally unreasonable, or brought for an improper purpose.
- A failure to satisfy an administrative precondition to suit (such as filing an EEOC charge before bringing an ADA action) may justify dismissal without prejudice, but it does not automatically justify Rule 11 sanctions where the defect is procedural and can be cured.
- In deciding whether sanctions are appropriate, a court may consider whether sanctions are necessary to deter similar conduct in the future and whether imposing sanctions for a curable procedural mistake would deter the filing of nonfrivolous discrimination claims.

## Conclusion

In *Bridges v. Diesel Service, Inc.*, the court held that although Bridges’s attorney filed an ADA employment-discrimination lawsuit before Bridges filed a required EEOC charge, that failure to exhaust administrative remedies was a procedural mistake that warranted dismissal without prejudice but did not, without more, meet the Rule 11 standard for monetary sanctions; because Rule 11 is chiefly a deterrence tool and the record did not show a frivolous claim or improper purpose, the court denied Diesel’s request for sanctions.


Bridges v. Diesel Service, Inc., 1994 U.S. Dist. LEXIS 9429 (1994)