Virginia Properties, LLC v. T-Mobile Northeast LLC, No. 16-2973 (2d Cir. 2017)Annotate this Case
The Supreme Court addressed in Goodyear Tire & Rubber Co. v. Haeger, 137 S. Ct. 1178, 1183‐84 (2017), a federal court's inherent authority to sanction a litigant for bad‐faith conduct by ordering it to pay the other side's legal fees. The Court held that such an order is limited to the fees the innocent party incurred solely because of the misconduct—or put another way, to the fees that party would not have incurred but for the bad faith. This appeal stemmed from a suit against T-Mobile for property damage to a building T-Mobile had leased space on the roof of for cell tower equipment. The Second Circuit vacated and remanded the district court's order of sanctions because it was in serious tension with the Court's holding and because the district court was mislead by defendants' submissions in awarding such severe sanctions.