Sidlosca v. Olympus Insurance Company
After the insured voluntarily dismissed her first-party property insurance suit, the insurer obtained a fee award based on a section 57.105 sanctions motion filed after the dismissal. The Third District reversed, holding a trial court retains continuing jurisdiction over a 57.105 motion only if the motion was filed with the court before the voluntary dismissal, and that a court likewise lacks inherent authority to impose inequitable-conduct sanctions after a voluntary dismissal.
Key facts
- Insured voluntarily dismissed her first-party property insurance suit against Olympus Insurance Company.
- After the voluntary dismissal, the insurer filed a section 57.105 sanctions motion and obtained a fee award from the trial court.
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Why it matters
A clean, citable rule for defense and plaintiff's counsel in first-party property cases: a post-dismissal 57.105 motion is jurisdictionally too late, and the inequitable-conduct doctrine cannot be used as a backup basis… — full analysis with a trial
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