United States Ninth Circuit

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Mount Hope Church v. Bash Back!, 11-35632

In a religious organization's suit against a subdivision of a national anarchist group under the federal Freedom of Access to Clinic Entrances Act and common law trespass, district court's sanction order granting attorneys' fees and costs to non-parties, which followed the quashing of a subpoena seeking identifying information for seven e-mail account holders, is reversed where Rule 45(c)(1) cannot properly support a sanction where the cost of complying with the subpoena is minimal and there is no showing that the subpoena was facially defective or issued in bad faith.

Appellate Information

  • Decided 11/26/2012
  • Published 11/26/2012


  • Gould


  • United States Ninth Circuit