Rhonda Barken sued Atlanta and public-works employees after her husband was killed in a motorcycle crash involving a reversible traffic lane. The trial court later imposed attorney fees and litigation expenses on Barken’s law firm under Georgia’s sanctions statute, reasoning that the firm had pursued claims without adequate support. The Court of Appeals of Georgia reversed. It held that the trial court applied the wrong negligence standard when imposing sanctions on its own initiative and had not made the findings required to connect the award to sanctionable conduct. Because that error required reversal, the court did not reach the firm’s remaining challenge to the amount of the fee award. The judgment against the firm was reversed.