NJ District Court awards employer Rule 11 sanctions for frivolous suit

On March 31, 2023, the U.S. District Court for the District of New Jersey imposed Rule 11 sanctions in favor of an employer based on the filing of a frivolous second amended complaint. The case serves as an important reminder that filing frivolous claims won’t be tolerated by the court, and when warranted, employers should request sanctions.

Facts

Tiffany Robertson and Fedeline Desire, two African-American females who worked for apparel company Dreamwear, filed an amended complaint alleging their employer unlawfully discriminated against them and that they suffered “dueling indignities of sexual harassment, racial discrimination, and diminished economic opportunities because [the company] foster[ed] a hostile work environment and enforce[d] a de facto racial hierarchy among its staff.”

The second amended complaint also alleged that although the few African-American women employed by the company possess exceptional qualifications and perform well, they experienced discrimination and limited opportunities to advance their pay. Robertson and Desire further alleged they filed complaints while working at Dreamwear, and the company failed to investigate their race and sex discrimination claims or remedy the harassment.