Massachusetts Appeals Court held today that when both the parties and their attorneys commit fraud on the court, that (1) frivolous action damages under G. L. c. 231, § 6F do not apply in District Court cases, and (2) that Rule 11 (Massachusetts Rules of Civil Procedure) sanctions cannot be imposed upon the parties themselves, just their attorneys. Tilman v. Brink, No. 08-P-498, August 18, 2009.