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Primo Hospitality Group, Inc. v. Haney, 283030

Reversed. Plaintiffs filed a legal malpractice action and then retained a new attorney. The Defendant served the new attorney with a motion for sanctions under CCP 128.7. The trial court granted the motion. The Appeals court held that a sanctions order cannot be supported solely by evidence of conduct occurring after the motion is served and must describe specific conduct and allow a safe harbor period for withdrawal or other appropriate and correct conduct.

Appellate Information

  • Decided
  • Published 2019/07/05


  • Moor


  • California Court of Appeal


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