State v. S.H.
Court of Appeals of Washington
1Opinion of the CourtKennedy, J.
— Seattle-King County Public Defender Association (PDA) appeals the juvenile court judge’s order assessing a $50 sanction against it for failing to enter into a diversion agreement “as expeditiously as possible” as required by RCW 13.40.080(1). A trial court has the inherent authority to assess sanctions against attorneys for abusive litigation conduct if it finds bad faith. Although the record here might support such a finding, the trial judge did not make an express finding of bad faith. Accordingly, the basis for the imposition of sanctions is not clear. We remand for entry of express…
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