Overlawyered pointed out this 9th Circuit case in which the District Judge made the loser pay for the expenses of the Respondents in defending against his frivolous claims.
It seems that the frivolous litigant sued the airport and its municipality because his private jet exceeded their weight restrictions. He had to use a smaller private jet to fly in and visit his vacation home. Awwwww!
The Court of Appeals remanded for a better explanation of the District Court's method of calculation... but it doesn't look like that's going to be a problem.