Jones v. National Railroad Passenger Corporation

Background

Amanda Jones’s Third Amended Complaint asserted claims under the Americans with Disabilities Act against National Railroad Passenger Corporation (Amtrak) and Santa Cruz Metropolitan Transit District (SCMTD), a Section 504 claim under the Rehabilitation Act against both defendants, a California Unruh Civil Rights Act claim against both defendants, and negligence claims against both defendants. The claims arose from an August 25, 2014 incident in which Jones’s motorized scooter tipped over while Jones was riding on a Highway 17 bus traveling from Santa Cruz to San Jose.

After rulings on cross-motions for summary judgment and an appeal to the Ninth Circuit, negligence against both defendants was the only claim remaining for trial. The first jury trial ended in a mistrial when the jury could not reach a unanimous verdict. The court later granted Amtrak’s renewed motion for judgment as a matter of law. A second trial also ended in a mistrial. At the third trial, the jury returned a unanimous verdict for Jones against SCMTD, and the court entered judgment as to both defendants on March 19, 2025.

Amtrak then moved for sanctions against Jones’s counsel Carla Aikens and the law firm of Carla Aikens, PC, and Catherine Cabalo and the law firm of Peiffer Wolf Carr & Kane. Amtrak relied on 28 U.S.C. § 1927, which can require an attorney who unreasonably and vexatiously multiplies court proceedings to pay resulting excess costs and fees, and on the court’s inherent power to sanction bad-faith conduct.

Timeliness and Evidentiary Objections

The court found Amtrak’s motion timely because it was filed within 14 days after the court entered judgment in Amtrak’s favor on March 19, 2025. The court rejected Jones’s argument that the filing period began when the court granted Amtrak’s judgment-as-a-matter-of-law motion in June 2023. The court also held that the local rule governing bills of costs did not bar a sanctions motion brought under Section 1927 and the court’s inherent power.

The court overruled Amtrak’s objections to materials Jones submitted with the opposition. It explained that the objections violated a local rule requiring evidentiary and procedural objections to be included in the reply, and that the materials need not satisfy all trial-evidence requirements because the court was deciding whether sanctions were appropriate, not Amtrak’s liability.

Sanctions Analysis

Amtrak argued that Jones’s counsel acted in bad faith by continuing the case against Amtrak through trial and post-trial motions despite allegedly lacking evidence that Amtrak owed Jones a duty of care. Jones’s counsel argued that the claim was reasonably pursued because evidence indicated a relationship between Amtrak and SCMTD and because the negligence claim against Amtrak had survived summary judgment.

The court agreed that Jones had not presented enough evidence at trial for a jury to find Amtrak liable. But it distinguished an unsuccessful claim from a frivolous claim pursued in bad faith. The negligence claim had survived summary judgment, and testimony from multiple witnesses connected Amtrak to the bus and the events underlying the claim, even though the testimony was ultimately insufficient. The court therefore declined to infer that Jones’s counsel continued the case to harass Amtrak or impose unnecessary expense.

The court also found that Jones’s post-trial efforts to rely on materials not presented at trial did not establish bad faith, conduct tantamount to bad faith, or an abuse of the judicial process. Amtrak had not shown that this conduct unreasonably and vexatiously multiplied the proceedings.

Disposition

The court denied Amtrak’s motion for sanctions.