Pitcher v. Waldman - no requirement to hold sanctions hearing

In Pitcher v. Waldman, the First District affirmed the trial court's decision denying sanctions. The defendant argued that the complaint was based on claims that the plaintiffs knew had previously been released pursuant to the settlement of earlier litigation, and that the sole purpose of the complaint was to harass Waldman.  The trial court denied the motion. On appeal, the First District rejected the argument that a trial court must hold a hearing on a motion for sanctions; per R.C. 2323.51(B)(2) requires a hearing only if the court imposes sanctions.