## Facts

- Bill R. Ruszala, a server at Walt Disney World’s ‘Ohana restaurant, was investigated internally for suspected employee theft based on discrepancies between guests rung up and guests served.
- Disney security investigators interviewed Ruszala at Disney security offices, where he confessed to stealing money from the restaurant.
- An Orange County Sheriff’s deputy responded to Disney’s request, advised Ruszala of his rights, stopped questioning when Ruszala requested counsel, and arrested him for employee theft.
- Ruszala filed a six-count civil action against Walt Disney World Company, a Disney security investigator, and the Orange County Sheriff in his official capacity.
- As to the sheriff, the complaint asserted only false arrest and a 42 U.S.C. § 1983 conspiracy theory; the asserted basis was that the arresting deputy allegedly lacked “personal knowledge” of the facts establishing probable cause.
- The sheriff sought summary judgment and repeatedly requested voluntary dismissal through counsel letters warning of potential Rule 11 sanctions.
- In deposition, Ruszala admitted probable cause existed for his arrest.
- The court granted summary judgment for the sheriff and ordered Ruszala and his attorney to show cause why Rule 11 sanctions should not issue for maintaining the claims against the sheriff.

## Issues

1. Whether continuing to litigate false arrest and § 1983 conspiracy claims against the sheriff, after probable cause was clear and admitted, violated Federal Rule of Civil Procedure 11 for lack of a reasonable factual or legal basis.
2. If Rule 11 was violated, what sanction was appropriate and no more severe than necessary to deter repetition, including whether fees and costs should be awarded and against whom.

## Decision

- The court found a Rule 11 violation based on the continued assertion of objectively frivolous claims against the sheriff.
- The court concluded there was no reasonable basis to maintain false arrest or § 1983 conspiracy claims once probable cause was established and admitted.
- The court held that reliance by an arresting officer on information from witnesses and private security personnel may support probable cause and does not require the officer’s personal observation of the underlying misconduct.
- The court imposed Rule 11 sanctions requiring payment of the sheriff’s reasonable attorney’s fees and costs incurred in defending the frivolous claims.

## Legal Principles

- Rule 11 applies an objective reasonableness standard to filings and later advocacy; sanctions may be imposed when claims lack a reasonable factual basis or a nonfrivolous legal basis after reasonable inquiry.
- Rule 11 imposes a continuing obligation to reassess claims as the record develops and to withdraw claims that become unsupportable.
- Rule 11 sanctions do not require proof of subjective bad faith; objective frivolousness can suffice.
- Sanctions must be limited to what is sufficient to deter repetition and may include shifting reasonable attorney’s fees and expenses directly caused by the violation.
- Probable cause defeats false arrest claims, and an officer may form probable cause based on reasonably reliable information supplied by others.

## Conclusion

The court sanctioned the plaintiff and/or counsel under Rule 11 for persisting in false-arrest and § 1983 conspiracy claims against the sheriff after the record—including the plaintiff’s own admission—showed probable cause for the arrest, ordering payment of the sheriff’s reasonable defense fees and costs as the least severe adequate deterrent.


Ruszala v. Walt Disney World Co., 132 F. Supp. 2d 1347 (M.D. Fla. 2000)