In April 1988, 55 Libyan citizens, including Saltany (plaintiff), filed suit against President Reagan (defendant) and others, including the United Kingdom, demanding damages for injuries and losses suffered as a result of the 1986 United States air strike on Libya. The district court dismissed the claims, and the court of appeals affirmed. The defendants also moved for sanctions against plaintiffs’ counsel under Rule 11. Although the district court found that plaintiffs’ counsel must have known that there was no possibility of success, it did not impose sanctions, citing the public policy of keeping courts accessible to plaintiffs who wish to bring cases against the government as a form of protest. The United Kingdom appealed the Rule 11 ruling, and in addition, requested attorneys’ fees for the cost of defending the case. The court of appeals reversed and remanded, finding that the Rule 11 sanction and attorneys fees were appropriate. Saltany appealed.