Pomeranz & Landsman Corp. v. Miami Marlins Baseball Club, L.P.

The petition for writ of prohibition is granted. The trial court lacks jurisdiction to hear the pending motion for sanctions under section 57.105, Florida Statutes (2013). The motion for sanctions in this case was filed after petitioner voluntarily dismissed the action. Generally, a voluntary dismissal under Florida Rule of Civil Procedure 1.420(a)(1) terminates a trial court’s jurisdiction over a matter. See Randle-Eastern Ambulance Serv., Inc. v. Vasta, 360 So.2d 68 (Fla.1978). Pursuant to Pino v. Bank of New York, 121 So.Bd 23, 41-43 (Fla.2013), a trial court has continuing jurisdiction to…