The LegalTimes blog reports that the D.C. Circuit has upheld a district court ruling that "[a]n art dealer ... must pay more than $630,000 in attorney fees and expenses to Christie’s for a suit [the district court] judge said only served to harrass the auction house after it refused to sell a painting." The (one-paragraph) decision is here. The district court decision is here.
The facts are a bit, um, unusual. According to the LegalTimes, the plaintiff, a Stanford Law School graduate named Robert Fastov, initially sent Christie’s "a 79-page, single-spaced letter—with hundreds of attachments—threatening litigation" and followed that up with a 225-page complaint. The lower court decision noted that "anyone with a modicum of common sense would have realized [the lawsuit] was without merit."