VIRGINIA GIUFFRE v. BRADLEY J. EDWARDS, 226 So. 3d 1034

Virginia Giuffre (nonparty) moved for sanctions and to strike Alan Dershowitz’s affidavit and pleadings after he disclosed communications that she alleged were confidential settlement communications in a prior case.
Dershowitz filed a motion in limine attaching an affidavit recounting meetings with Attorney Boies; The New York Times later published parts of that affidavit.
Giuffre sought emergency sealing, a motion to strike, and sanctions; the trial court temporarily sealed the affidavit and reserved ruling on sanctions.
After a subsequent deposition where Dershowitz allegedly repeated the communications, Giuffre filed supplemental sanctions motions; Dershowitz moved to strike those motions.
The parties to the defamation suit (Dershowitz and the attorneys) filed a joint stipulation of dismissal with prejudice; the trial court then struck Giuffre’s sanctions motions, concluding it lacked jurisdiction post-dismissal and that Giuffre (a nonparty) lacked standing.
The appellate court held the trial court erred about jurisdiction (sanctions motions were collateral and court retained jurisdiction) but correctly concluded Giuffre lacked standing, affirming on that ground.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court retained jurisdiction to decide Giuffre’s sanctions motions after parties filed a stipulation of dismissal	Giuffre: sanctions are collateral/independent matters (attorney’s fees, enforcement of court orders) so court retains jurisdiction post-dismissal	Dershowitz: voluntary dismissal divested court of jurisdiction over any further matters	Court: Jurisdiction continued; sanctions for discovery abuses and enforcement of court orders are collateral and the court retained authority
Whether a nonparty (Giuffre) has standing to seek sanctions and relief in the underlying case	Giuffre: suffered reputational injury from disclosure; relief (striking pleadings, fees, admonishment) would remedy harm	Dershowitz: Giuffre is a nonparty and thus lacks standing to control proceedings or seek relief in that case	Court: Giuffre lacked standing; as nonparty she could not show relief would likely remedy her injury, so dismissal of her motions affirmed

Miller v. Fortune Ins. Co., 484 So. 2d 1221 (Fla. 1986) (trial court’s jurisdiction ends with termination of litigation)
Randle-E. Ambulance Serv., Inc. v. Vasta, 360 So. 2d 68 (Fla. 1978) (voluntary dismissal removes court’s power to enter orders unless exceptions apply)
Amlan, Inc. v. Detroit Diesel Corp., 651 So. 2d 701 (Fla. 4th DCA 1995) (monetary sanctions for discovery abuses are collateral and may be considered after final judgment)
Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990) (courts may adjudicate contempt and impose sanctions after action termination)
Pino v. Bank of New York, 121 So. 3d 23 (Fla. 2013) (trial court retains jurisdiction to resolve pending sanctions motions despite voluntary dismissal)
State v. J.P., 907 So. 2d 1101 (Fla. 2005) (three minimal constitutional requirements for standing)