Michael Manfredi (Partner-Atlanta, GA) and Jennifer Sands (Associate-Atlanta, GA) obtained dismissal of all claims against the firm's client in a federal action in which the plaintiff sought $3,000,000 in damages. The plaintiff asserted claims against multiple defendants, alleging violations of his constitutional rights under both federal and state law, and negligence under Georgia state law. The plaintiff further sought attorney's fees under O.C.G.A. § 13-6-11, alleging our client acted in bad faith and was stubbornly litigious. The federal district court granted the motion to dismiss in its entirety without oral argument, notwithstanding the plaintiff's request for a hearing.