COA: No Right To Jury Trial For Rule 11 Factual Disputes

Today in Hill v. Hill the COA held that a party isn't entitled to a jury trial to resolve factual disputes underlying a Rule 11 motion (e.g., whether a claim was filed for an improper purpose). The COA had held 20 years ago that trial court orders imposing discovery sanctions don't violate the right to a jury trial. Today's decision is consistent with that decision, and it's consistent with Rhyne v. K-Mart Corp. (N.C. 2004), which held that the statutory cap on punitive damages doesn't violate the right to a jury trial.