¶60 Sanctions, including attorney fees, may be imposed under the court's inherent equitable powers to manage its own proceedings. State v. Gassman , 175 Wash.2d 208, 210-13, 283 P.3d 1113 (2012). To impose attorney fee sanctions under the court's equitable powers, it is sufficient and best practice for a court to make a finding of bad faith.
This court reviews imposition of sanctions for abuse of discretion. State v. Gassman, 175 Wn.2d 208, 210, 283 P.3d 1113 (2012). "A trial court has the inherent authority to sanction lawyers for improper conduct during the course of litigation, but that generally requires a showing of 'bad faith.'"
A trial court may impose sanctions according to court rules or under its own inherent equitable powers. State v. Gassman, 175 Wn.2d 208, 210-11, 283 P.3d 1113 (2012). A trial court's inherent authority to manage and control its calendar, proceedings, and parties allows the court to award attorney fee sanctions based on a finding of bad faith.
"Sanctions, including attorney fees, may also be imposed under the court's inherent equitable powers to manage its own proceedings." State v. Gassman. 175 Wn.2d 208, 210-11, 283 P.3d 1113(2012). The trial courts' "inherent authority to control and manage their calendars, proceedings, and parties" allows attorney fees sanctions based on a finding of bad faith.
We review sanction decisions for abuse of discretion.State v. Gassman, 175 Wn.2d 208, 210-11, 283 P.3d 1113(2012).
¶51 Dalton M cites cases arising in the sanctions context, arguing that "[a]n appellate court may still uphold a sanction ‘where an examination of the record establishes that the court found some conduct equivalent to bad faith,’ " even if the court made no explicit finding of bad faith. State v. Numrich , 197 Wash.2d 1, 27, 480 P.3d 376 (2021) (quoting State v. Gassman , 175 Wash.2d 208, 211, 283 P.3d 1113 (2012) ). But even under these cases, the appellate court cannot affirm a sanction unless the record shows bad faith conduct related to the conduct for which the party was sanctioned.
A trial court has the authority to impose sanctions, including attorney fees, under its inherent equitable powers to manage its own proceedings. State v. Gassman, 175 Wn.2d 208, 210-11, 283 P.2d 1113 (2012). Its inherent authority to sanction litigation conduct
Again our review is for abuse of discretion. State v. Gassman, 175 Wn.2d 208, 210, 283 P.3d 1113 (2012). This time we agree with Mr. Saha.
Indeed, "[t]rial courts have inherent authority to control and manage their calendars, proceedings, and parties." State v. Gassman, 175 Wn.2d 208, 211, 283 P.3d 1113 (2012) (citing CowlesPubl'g Co. v. Murphy, 96 Wn.2d 584, 588, 637 P.2d 966 (1981)).
Indeed, "[t]rial courts have inherent authority to control and manage their calendars, proceedings, and parties." State v. Gassman, 175 Wn.2d 208, 211, 283 P.3d 1113 (2012) (citing Cowles Publ'g Co. v. Murphy, 96 Wn.2d 584, 588, 637 P.2d 966 (1981)).