Yulex Barker, a former United Airlines employee, sued the airline following her termination in April 2021. After her second amended complaint was dismissed with prejudice by the District Court for failing to allege a link between her disability and termination and for forfeiting subject matter jurisdiction arguments, Barker filed a motion under Federal Rule of Civil Procedure 59(e) seeking to alter or amend the judgment. Barker argued that new evidence, specifically a 2023-2025 collective bargaining agreement, was now available and that her dismissal resulted in manifest injustice. United Airlines moved for sanctions under Rule 11, arguing the motion was frivolous. The District Court denied the Rule 59(e) motion, finding the assertion of new evidence to be demonstrably untrue, and granted the Rule 11 motion, imposing a $2,500 sanction on Barker's counsel. Barker appealed this sanction order.
The Third Circuit reviewed the district court's Rule 11 determination for abuse of discretion. The court emphasized that Rule 11 imposes an affirmative duty on counsel to conduct an inquiry reasonable under the circumstances to ensure that factual contentions have evidentiary support. The court found that Barker's Rule 59(e) motion was patently frivolous because her claim that the 2023-2025 collective bargaining agreement was new evidence was demonstrably untrue. The record showed that Barker's second amended complaint had already referenced and attached a portion of a 2016-2021 collective bargaining agreement containing provisions identical to those in the 2023-2025 agreement. Furthermore, since Barker's employment terminated in April 2021, the 2023-2025 agreement was not relevant to her employment period and could not constitute new evidence of a claim that should have been raised earlier. The court also rejected the argument that there was manifest injustice in precluding the new ERISA claim, noting that Barker could have asserted it from the beginning. Because the motion was based on a false assertion and served to relitigate matters already decided, the district court did not abuse its discretion in imposing sanctions.
The $2,500 sanction against Barker's counsel remains in effect. This decision reinforces the strict duty of counsel to verify the factual basis of motions to alter or amend judgment under Rule 59(e) and clarifies that such motions cannot be used as a vehicle to introduce evidence that was available prior to judgment or to relitigate issues already decided.
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