Sanctions details from the ruling in L-Strategies LLC v. Angie Wong (U.S. District Court, Northern District of Georgia, Case 3:23-cv-207-TCB, Judge Timothy C. Batten Sr.):
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Judge Batten granted Angie Wong’s motion for sanctions against plaintiff L-Strategies LLC and its attorney, Jared Craig. This followed the partial dismissal of the plaintiff’s claims (fraud, embezzlement, defamation, etc.), which the court found largely failed to state a viable claim due to insufficient evidence and legal deficiencies.
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Key Elements of the Sanctions Order
• Basis for sanctions: The court determined that attorney Jared Craig’s conduct in filing and pursuing the lawsuit warranted sanctions. Judge Batten noted that while courts generally disfavor sanctions against lawyers, failing to impose them here would unfairly force Wong to bear the financial burden of defending against meritless claims.
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• Standard applied: The judge cited precedent that sanctions are appropriate when actions are “at a minimum… ‘objectively reckless.’” This is an objective standard (not requiring proof of subjective bad faith or malice). Recklessness in raising frivolous arguments or failing to understand/apply the law suffices.
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• What was awarded: Wong receives her costs, expenses, and attorney’s fees incurred specifically because of Craig’s conduct. The exact amount would be determined later (via submission of billing records or a separate motion), but it directly compensates her defense costs tied to the improper litigation.
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• Context in the ruling: The complaint was criticized for lacking sufficient factual or legal support. The sanctions serve as a deterrent against using litigation to harass or silence critics (in this case, Wong’s reporting on alleged issues with the plaintiffs’ organizations).
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This is under the court’s authority (likely including 28 U.S.C. § 1927 for unreasonably multiplying proceedings, and/or inherent powers), common in federal cases for baseless filings. It does not necessarily imply fraud by the attorney but highlights reckless disregard for the merits.
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Wong has framed this as a broader victory against “lawfare,” and she runs Operation Bullyproof to help others facing similar tactics. The ruling is from around mid-2024 (based on related filings and announcements), with the recent post highlighting its significance.
For the full order, it would be available via PACER (docket entries around the motion for sanctions hearing and final order in that case).