This may seem like business as usual for our state court practitioners, but apparently even federal district judges can forget to provide a basis for appellate review:
Abuse of discretion review, however, requires something for us to review. When ruling on a motion for attorney’s fees or sanctions, the district court must provide an explanation of the basis for its ruling that is sufficient to allow for meaningful appellate review.Dear clerk readers, please now plan on heading to South Beach for drinks thirty minutes later than usual.
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Although the district court did find that Arugu’s motion for voluntary dismissal was itself not made in bad faith, its denial of the City’s motion for sanctions and attorney’s fees was not accompanied by any explanation, analysis, or findings. The court gave no reason for rejecting the City’s contentions that Argu had filed a frivolous § 1983 claim and had unreasonably multiplied the proceedings. We therefore vacate the order denying sanctions and attorney’s fees and remand for the district court to revisit the issue, make appropriate findings, and explain its decision.