Project Creation, Inc. v. Kenneth Neal
This case involves an appeal concerning sanctions imposed on Project Creation, Inc. and Sean Meek after their libel lawsuit was dismissed. The original libel action was filed against neighbors who wrote a letter to a local newspaper opposing Project Creation's proposed 'Ark Museum and Dinosaur Park' project, alleging deception and misleading statements related to zoning. The trial court found the libel action was filed for an improper purpose and lacked factual support under Tenn. R. Civ. P. 11, awarding the defendants $9,262.90 in attorney fees and expenses. The Court of Appeals affirmed the trial court's decision to impose sanctions, holding that an objective reasonableness standard applies to represented parties, even if they did not sign the offending document. However, the appellate court vacated the monetary award, remanding the case for a recalculation of sanctions to include only those fees and costs directly resulting from the libel lawsuit, not from the intertwined zoning dispute.