In this case, such an award is necessary in order to deter similar futureconduct. Ms. Jordan pursued this appeal despite being placed on notice byboth the trial court and Respondent's counsel that there was
The trial court found that
Jordan "cannot have beenunaware"
the numerous prior decisions rejecting challenges to thePresident's qualifications.
Ms. Jordan additionally receivedwarning from Respondent's counsel. Declaration
Even in Support
Motion for Attorney's Fees,
Ms. Jordan not only decided to proceed in disregard
thesewarnings, but the record contradicts her assertion that "there
no claimshe acted in bad faith or [with] malicious intent." Motion
Ms. Jordan repeatedly lodged reckless allegations
"collusion" betweenthe superior court judge and the Secretary's counsel.
Respondent'sMotion for Attorney Fees
6-9. Ms. Jordan did
despite possessinginformation demonstrating her conspiratorial allegations to be unfounded.
Respondent's Reply in Support
Motion forAttorney's Fees at 3-5.
See, e.g., Rhodes
670 F. Supp.2d 1363, 1382 (M.D. Ga. 2009)(imposing $20,000 sanction against attorney who had challenged deployment
an armyofficer to Iraq based on the notion that the qualifications
the commander-in-chiefwerein doubt);
179, 180 (D.D.C. 2009) (describing achallenge to the President's qualifications as a case that,
it were allowed to proceed,would deserve mention in one
those books that seek to prove that the law
foolish orthat America has too many lawyers with not enough to do");
Liberty Legal Foundation
National Democratic Party
2012 WL 3683492,
(W.D. Tenn. 2012)(imposing sanctions based on contention that the President
not a natural-born citizen).3