Yeh v. Hnath, 294 A.3d 1081

Yeh and Hnath had a long-term romantic relationship (cohabitation, joint accounts, joint property) but never married or registered a domestic partnership; they separated in 2017–2018.
After Hnath filed a partition action in 2019, Yeh sued for a divorce claiming a common-law marriage beginning in 2008; Hnath countered and sought discovery.
Hnath obtained a 2018 deposition transcript in which Yeh said she was not married and had described the parties as "domestic partners." He threatened sanctions by email, then later filed for summary judgment and, after summary judgment was granted for Hnath, a standalone sanctions motion seeking attorneys’ fees.
The Superior Court granted summary judgment for Hnath and, finding Yeh acted in bad faith, awarded $74,227.36 in fees under both Super. Ct. Dom. Rel. R. 11 and the court’s inherent authority.
On appeal the D.C. Court of Appeals reversed: (1) Rule 11 sanctions were procedurally improper because Hnath did not comply with the rule’s 21-day safe-harbor and standalone-motion requirements; and (2) the record lacks clear and convincing evidence of the exceptional bad faith required to invoke the court’s inherent authority to shift fees.

Issue	Plaintiff's Argument (Yeh)	Defendant's Argument (Hnath)	Held
Whether Rule 11 safe-harbor satisfied	Email threat insufficient; no 21-day service; sanctions improper	Email and earlier filings adequately notified Yeh	Held: Safe-harbor not satisfied; Rule 11 sanction improper
Whether Yeh’s complaint was frivolous	Claim was colorable based on cohabitation, joint property, reputation	Claim was meritless and filed to harass/delay	Held: Although meritless, claim was colorable; not basis alone for sanctions
Whether inherent authority supports fee award (bad faith)	Conduct did not meet clear-and-convincing bad-faith standard	Discovery delay, nondisclosure of transcript, timing show bad faith	Held: No clear-and-convincing evidence of egregious bad faith; inherent sanction improper
Whether fee award was appropriately analyzed	Court failed to consider ability to pay, deterring minimum, reasonableness	Hnath sought full claimed fees	Held: Trial court did not perform required Williams-factor analysis; award infirm (also moot because sanctions reversed)

Gill v. Nostrand, 206 A.3d 869 (D.C. 2019) (test for common-law marriage elements)
Goldschmidt v. Paley Rothman Goldstein Rosenberg & Cooper, Chartered, 935 A.2d 362 (D.C. 2007) (Rule 11 safe-harbor is mandatory)
Goldberg. Marchesano. Kohlman. Inc. v. Old Republic Sur. Co., 727 A.2d 858 (D.C. 1999) (notice letter is not equivalent to Rule 11 service)
In re Jumper, 909 A.2d 173 (D.C. 2006) (inherent-authority/bad-faith sanctions standard)
In re Jumper, 984 A.2d 1232 (D.C. 2009) (clear-and-convincing proof required for bad-faith finding)
Synanon Found., Inc. v. Bernstein, 517 A.2d 28 (D.C. 1986) (American rule and narrow exceptions for fee shifting)
Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (courts’ inherent authority to sanction for abuse of process)
Jung v. Jung, 844 A.2d 1099 (D.C. 2004) (colorable-claim standard; caution in imposing fees)
In re Est. of Delaney, 819 A.2d 968 (D.C. 2003) (bad-faith exception applied only in extraordinary circumstances)
Williams v. Bd. of Trs. of Mount Jezreel Baptist Church, 589 A.2d 901 (D.C. 1991) (factors courts should consider when setting monetary sanctions)