Monbo v. Nathan, 1:18-cv-05930

Plaintiffs Taje and Deafueh Monbo (pro se) sued multiple defendants in 2018 alleging copyright and trademark infringement related to 2001 and 2003 documentaries about the 12 O’Clock Boyz.
The Court dismissed Plaintiffs’ claims on August 26, 2022; Plaintiffs then moved for recusal, which the Court denied in December 2022.
On December 28, 2022, Plaintiffs filed a submission alleging, on information and belief, that the presiding judge had accepted bribes from defendants to favor them and to avoid seeking a Register of Copyrights inquiry.
The Court found those allegations baseless and issued an Order to Show Cause under Fed. R. Civ. P. 11(c) on January 18, 2023, directing Plaintiffs to explain why they should not be sanctioned for violating Rule 11(b).
Plaintiffs did not respond to the show-cause order; defendants requested Rule 11 sanctions.
The Court concluded the allegations were frivolous and motivated by an improper purpose (to force recusal) and imposed a $500 sanction on each plaintiff, payable to the Clerk by June 2, 2023.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Plaintiffs’ allegations of judicial bribery and bias violated Rule 11(b)	Alleged, on information and belief, that the judge accepted bribes from defendants to issue favorable rulings and avoid an inquiry with the Register of Copyrights	Alleged claims were baseless, unsupported by evidence, and made to harass and force recusal; sought sanctions	Court held allegations were entirely without color, motivated by improper purpose, and violated Rule 11(b); sanction imposed
Effect of Plaintiffs’ failure to respond to the show-cause order	No substantive response to the Order to Show Cause was offered	Pointed to Plaintiffs’ nonresponse to support imposition of sanctions	Court found failure to respond reinforced that allegations lacked evidentiary support and warranted sanctions ($500 each)

Caisse Nationale de Credit Agricole-CNCA v. Valcorp, Inc., 28 F.3d 259 (2d Cir.) (Rule 11 sanctions may be imposed for improper purpose or without reasonable inquiry)
Wolters Kluwer Fin. Servs. Inc. v. Scivantage, 564 F.3d 110 (2d Cir.) (sanctions appropriate where conduct is entirely without color and motivated by improper purposes)
Huebner v. Midland Credit Mgmt., Inc., 897 F.3d 42 (2d Cir.) (same standard for imposing sanctions)
Ransmeier v. Mariani, 718 F.3d 64 (2d Cir.) (false accusations of judicial bias undermine integrity of judicial process)