Williams v. Hung

Citations

• 257 N.E.3d 323
• 2024 Ohio 5093

Syllabus

Sanctions; Civ.R. 11; Civ.R. 45; attorney fees; waiver; reasonableness of fees; sworn evidence; fee bills; disqualification order; mootness; ability to pay. Judgment affirmed. The court's award of sanctions in the form of attorney fees to the plaintiff and two nonparties is affirmed where the record demonstrates that the sanctioned party contested the reasonableness of the fees and the trial court rejected the sanctioned party's arguments and did not abuse its discretion in rejecting the sanctioned party's arguments. Additionally, the sanctioned party's attempt to dispute fees stemming from his disqualification as counsel are moot because no fees were awarded stemming from the disqualification and the trial court did not err in failing to consider the sanctioned party's ability to pay where such evidence was not introduced before the trial court made its decision, despite numerous opportunities to present such evidence.