Dexter v. Spokane County Health District

This action involves a fraud claim brought by Forrest Dexter against Robert Dixon. The trial court granted summary judgment in favor of Mr. Dixon on the basis of issue and claim preclusion and awarded sanctions pursuant to CR 11. Mr. Dexter contends: (1) the subject matter of this suit is distinct from that in controversy in previous litigation; (2) his position was not so unfounded as to warrant sanctions; (3) even if sanctions were appropriate, the award is not supported by findings; and (4) the order awarding sanctions is void because it was entered in the absence of a presentment hearing.…