But along with such landmark cases have come a bounty of frivolous and groundless complaints.

In November, 1777, Burgoyne wrote a rash and groundless complaint of its violation by the Americans, and raised the implication that he might use the pretended breach to disengage himself and his government from all its obligations.

Alton H. Maddox Jr. has been ordered by a Federal judge in Manhattan to pay New York State $1,000 in legal costs for filing a groundless complaint of racial discrimination last year against more than a dozen state judges and court administrators.