Hadges v. Yonkers Racing Corp

Facts

Plaintiff Hadges sued Defendant Yonkers Racing Corp. in both state and federal court for barring Plaintiff from working at Defendant’s racetracks. The federal claim was based on violation of due process and was dismissed for lack of state action. There was also an affidavit filed by Defendant that the court understood to mean that Plaintiff could work at other tracks. The Court noted that if a racetrack in New Jersey followed Defendant’s decision, Plaintiff could establish state action. In the state suit, where Plaintiff claimed he was “blackballed” from working at all New York racetracks, all counts were dismissed. Plaintiff then sued Meadowlands Raceway, a New Jersey agency, in federal court on the same grounds as his original claim against Defendant, which was settled and included an affidavit, stated that Defendant’s ban provided a basis for Meadowlands’ ban. Plaintiff appealed the New York federal action under Rule 60(b) of the Federal Rules of Civil Procedure on the grounds that the original federal action should be vacated because the affidavit of Defendant which stated that Plaintiff could work at other tracks was fraudulent. Plaintiff and his attorney both submitted affidavits that said that Plaintiff had not worked in 4 years and presented evidence that a racing board had barred him from a race in 1989. It was later revealed that Plaintiff was barred from the race in 1987. Defendant moved to dismiss the action, and presented evidence that Plaintiff had raced in Monticello, another track, and also moved to impose sanctions for misrepresentation of the date Plaintiff was barred from the 1987 race and failing to disclose the state action to the federal court. The District Court dismissed the complaint but did not impose sanctions because the suit was not so frivolous as to warrant sanctions under Rule 11 of the Federal Rules of Civil Procedure. The District Court requested Plaintiff and attorney submit arguments against the imposition of sanctions. The District Court then imposed sanctions against Plaintiff for misrepresentation and his attorney for failure to investigate his client’s assertions and for not disclosing the state court action. Plaintiff’s attorney sent a letter to the Court, arguing that the Court erred in imposing sanctions against him and his client, and objecting to comments the Court made about the attorney in its order imposing sanctions. The District Court considered this letter an application to reargue the sanctions and wrote an order denying the application, which contained additional comments about Plaintiff’s attorney. Plaintiff appealed from these rulings.