This article examines the Townsend decision and its interpretation and application of Rule 11 sanctions. It further examines the development of Rule 11 sanctions in light of the liberal pleading standards introduced with the advent of the Federal Rules in 1938. Finally, the article reviews the criticisms and comments leveled at Rule 11, and speculates on its future and its impact on federal court litigation.
Annette M. Wilson,
Civil Procedure - Rule 11 Sanctions Revisited: Townsend v. Holman Consulting Corporation, 22 Golden Gate U. L. Rev.