Citizens Property Insurance Corp. v. Oppenheimer
Citizens filed a section 57.105 sanctions motion in August 2024 after the safe-harbor period on its first notice expired, then in January 2025 served a second safe-harbor notice and proposed sanctions motion raising the same grounds; the plaintiffs voluntarily dismissed their suit on day 16 of that second 21-day period. The Third District, addressing an issue of first impression, affirmed the denial of the earlier-filed motion, holding that by serving a successive motion on identical grounds Citizens gave the plaintiffs a fresh safe harbor, and their timely dismissal defeated sanctions.
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