Thomas C. Crumplar, Esquire v. the Superior Court of the State of Delaware in and for New Castle County

Summary

The court affirmed that Rule 11 violations are judged under an objective reasonableness standard rather than an attorney's subjective good-faith belief. It held that Crumplar's mistaken case citation and failure to address contrary authority did not violate that standard or prejudice the proceedings, and it vacated the sanctions. The court also held that a judge imposing Rule 11 sanctions sua sponte must provide an opportunity for the attorney to present evidence and respond orally, including an inquiry into ability to pay when monetary sanctions are contemplated.