Court must re-evaluate failure to award sanctions

Fresh Cut Lawn Maintenance sued Christopher Yatooma and others, attmpting to litigate a contract dispute. Yatooma made a written offer to pay $1,000.00, which Fresh Cut rejected, considering the offer a nuisance offer, given the amount at stake. When the trial judge later dismissed Fresh Cut's claim, Yatooma sought sanctions, including fees and costs, because Fresh Cut had not improved on the nuisance offer by ten percent. The judge refused to award sanctions, citing the "interests of justice" exception in the Court Rule. The Court of Appeals pointed out that the lower court's reasoning for denying sanctions was not adequate. Sanctions must be awarded, even if the refusal to settle is "reasonable" and the claim being pursued is not "frivolous." The case was sent back to the lower court to either provide a better rationale for not imposing sanctions, or to award sanctions.