While OCGA § 9-11-41 (b) authorizes the trial court to dismiss a plaintiff's complaint for violations of "any order of court" and OCGA § 9-11-41 (c) extends this authority to the dismissal of counterclaims, cross-claims, or third-party claims, it does not authorize a trial court to impose the sanction of "issue preclusion" against a defendant who violates a court order. The Plaintiffs cite Wood v. UHS of Peachford, L.P., 315 Ga. App. 130, 132, 726 S.E.2d 422 (2012), for the proposition that a trial court can impose issue preclusion sanctions due to a party’s repeated failure to comply with court orders. In Wood, we affirmed the trial court’s dismissal of a plaintiff's case due to the plaintiff's repeated failure to comply with the trial court’s orders, both during discovery and voir dire.

See, e.g., Fox v. First Bank , supra, 198 Conn. at 37–38, 501 A.2d 747 (failure to make payments to defendant in accordance with temporary restraining order, resulting in three findings of contempt in seven month period); Rodriguez v. Mallory Battery Co. , 188 Conn. 145, 150–51, 448 A.2d 829 (1982) (failure to revise complaint despite multiple orders over nine months); Bongiovanni v. Saxon , 99 Conn. App. 221, 226–29, 913 A.2d 471 (2007) (plaintiff's filing of false certificate of closed pleadings did not comply with order to file certificate by certain date); Burton v. Dimyan , 68 Conn. App. 844, 845–46, 793 A.2d 1157 (over period of nine months, plaintiff failed to comply with order to file certificate of closed pleadings), cert. denied, 260 Conn. 925, 797 A.2d 520 (2002). Courts in other jurisdictions similarly have upheld sanctions for repeated, wilful violations of court orders. See, e.g., Wood v. UHS of Peachford, L.P. , 315 Ga. App. 130, 131–32, 726 S.E.2d 422 (2012) (dismissal was appropriate sanction for counsel's repeated and flagrant violations of trial court's orders during discovery and voir dire).Although this court has not considered whether a single act of misconduct could warrant the sanction of nonsuit, courts in other jurisdictions have concluded that a single act could warrant nonsuit or dismissal if the act is sufficiently egregious, particularly when the improper conduct involves the perpetration of a deception on the court.