Betty Ali v. Richard L. Tolbert, et al

Plaintiff filed an action against defendants claiming that they violated the D.C. Consumer Protection Procedures Act ("CPPA"), DC Code 28-3904, by inducing her to sell her house to one of the defendants and then failing to pay her the full amount promised. At issue was whether the district court erred in granting summary judgment under Federal Rule of Civil Procedure 56 and sanctions under Federal Rule of Civil Procedure 11. The court affirmed summary judgment where the district court correctly concluded on the record before it that one of the defendants was not a merchant subject to the CPPA. The court vacated the sanction award against one defendant where the defendant's conduct did not involve representations to the court that was sanctionable under Rule 11.