Van Sant Law, LLC v. Air Isaac, LLC
After Air Isaac voluntarily dismissed its suit well after the section 57.105(4) twenty-one-day safe harbor expired, Van Sant Law pursued its pending sanctions motion. The trial court held a hearing, took the matter under advisement, and then entered an unelaborated order denying the motion without any oral or written findings. The Second District reversed, holding that while a denial of section 57.105 fees does not require the specific findings mandated for a grant, the total absence of any findings precludes meaningful appellate review, and remanded for the court to render findings.
Key facts
- Van Sant Law filed a motion for sanctions under section 57.105 against Air Isaac in the trial court.
- Air Isaac voluntarily dismissed its suit after the twenty-one-day safe harbor period under section 57.105(4) had expired, while Van Sant Law's sanctions motion was still pending.
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Why it matters
The opinion refines the widely cited rule (Sans Souci, Mason, Shortes) that no findings are needed to deny 57.105 fees, clarifying that a wholly unelaborated denial is still reversible because it frustrates appellate… — full analysis with a trial
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