Kinney v. R.H. Halt Associates, Inc.

SILBERMAN, Judge.

Michael J. Kinney appeals the trial court’s final order of dismissal with prejudice.1 The trial court entered the dismissal order after Kinney failed to comply with earlier court orders requiring the payment of attorney’s fees and costs as a discovery sanction. We reverse and remand for further proceedings because the trial court did not make an explicit finding of Kinney’s willful noncompliance or deliberate disregard of the earlier sanction orders.

Kinney sued Tandem Associates, a building owner; Cadstruct, the general contractor that was performing remodeling work on the…