Yulex Barker v. United Airlines Inc

── Yulex Barker v. United Airlines Inc ── Court: Court of Appeals for the Third Circuit Date: April 08, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 25-1539 YULEX BARKER, Appellant v. UNITED AIRLINES, INC.; JOHN DOES 1-5 _____________________________ Appeal from the U.S. District Court, D.N.J. Judge Susan D. Wigenton, No. 2:23-cv-03065 Before: PORTER, MONTGOMERY-REEVES, and BOVE, Circuit Judges Submitted Apr. 7, 2026; Decided Apr. 8, 2026 _____________________________ NONPRECEDENTIAL OPINION * PORTER, Circuit Judge. Yulex Barker asked the District Court to reconsider its dismissal of her second amended complaint. But that request was frivolous, based on a demonstrably untrue assertion. So the District Court sanctioned Barker’s counsel and required him to pay $2,500 to the defendant, United Airlines, Inc. We will affirm. I Barker is a former employee of United Airlines. After raising a time-card discrep- ancy, United Airlines terminated Barker’s employment in April 2021. Believing she was * This disposition is not an opinion of the full Court and, under 3d Cir. I.O.P. 5.7, is not binding precedent. wrongfully fired, Barker sued United Airlines in state court on various claims. Key to Barker’s case was her contention that she was denied her right to “progressive discipline” under the collective bargaining agreement governing her employment. After removal to federal court and a couple rounds of briefing, the United States District Court for the District of New Jersey dismissed with prejudice Barker’s second amended complaint (“SAC”) containing her three remaining claims. For her disability discrimination claim, the District Court held that Barker failed to allege any nonconclusory link between her disa- bility and termination. On her two contract-related claims, the District Court concluded that Barker had failed to respond to United Airlines’s argument for lack of subject matter jurisdiction and thus forfeited the issue. Thereafter, Barker filed a motion to alter or amend judgment under Federal Rule of Civil Procedure 59(e) seeking reconsideration of the District Court’s dismissal. Viewing Barker’s motion as frivolous and improper, United Airlines sent Barker a letter advising that it would move for sanctions under Federal Rule of Civil Procedure 11 unless Barker withdrew her Rule 59(e) motion within the 21-day safe harbor period. Barker declined to withdraw her Rule 59(e) motion, and United Airlines filed its Rule 11 motion for sanctions. The District Court denied Barker’s Rule 59(e) motion, finding its purported basis to be “demonstrably untrue,” and granted United Airlines’s Rule 11 motion for sanctions. After requesting and receiving an affidavit from United Airlines detailing its costs incurred in defending against Barker’s Rule 59(e) motion, the District Court imposed a sanction of $2,500 against Barker’s counsel. Barker timely appealed. 2  II 1 Under threat of sanctions, Rule 11 imposes on counsel an affirmative duty to con- duct an “inquiry reasonable under the circumstances” to ensure that their (1) “[filings are] not being presented for any improper purpose,” (2) “legal contentions are warranted by existing law or by a nonfrivolous argument,” (3) “factual contentions have evidentiary support,” and (4) “denials of factual contentions are warranted on the evidence.” Fed. R. Civ. P. 11(b). In other words, at the time of filing the challenged paper, counsel must have an “objective knowledge or belief” that the challenged paper’s basis is “well-grounded in law and fact.” Bens