Cramer

BACKGROUND

Cramer sued a number of California counties, cities, courts, and other entities asserting criminal conspiracies related to numerous incidents and legal proceedings in various jurisdictions. One of the named entities was the Association, a homeowners’ association of which Cramer was a member. Cramer’s amended complaint described certain disputes with neighbors regarding his yard and property stored on it, which apparently led him to file a separate suit in El Dorado County before filing this one. He alleged that the Association failed to adhere to its governing documents and conspired with the county to find that no violations had occurred. The Association filed a demurrer, asserting, among other arguments, that Cramer failed to engage in alternative dispute resolution before filing his suit against the Association, in contravention of the Davis-Stirling Act (Civ. Code, § 5930). Shortly before the scheduled demurrer hearing, Cramer filed a request for voluntary dismissal without prejudice as to the Association. The trial court clerk entered the voluntary dismissal. The Association then moved for an award of attorneys’ fees as the “prevailing party” pursuant to Civil…