Plere Publishers, Inc. v. Capital Cities/ABC, Inc.

Plaintiffs attorney appeals from an award of sanctions against him pursuant to ORCP 17. The sole issue that we discuss is whether the trial court’s findings are sufficient to allow us to review the award of sanctions.

After the dismissal of a second complaint in this case, defendant moved for sanctions pursuant to ORS 20.105. The trial court held on its own motion that it would instead apply ORCP 17, because it could not award sanctions against an attorney under ORS 20.105. The trial court found:

“The test as to whether sanctions should be imposed is whether plaintiffs attorney had a reasonable…