T. Barry Gray's List: SANCTIONS PA. R.C.P. 2503

• The two related issues presented in this case are: (1)
• ed uncontrollably in a westward direction in the eastbound lanes of a four-lane highway and (
• • definition at highlighted of arbitrary
• The statutory provision at 42 Pa.C.S. § 2503(9) expressly permits a trial court to award reasonable counsel fees to a litigant when, inter alia, that litigant's opponent initiated the action arbitrarily, vexatiously or in bad faith. Accord id. An opponent's conduct has been deemed to be "arbitrary" within the meaning of the statute if such conduct is based on random or convenient selection or choice rather than on reason or nature. Bucks County Board of Supervisors v. Gonzales, 158 Pa. Commw. 664, 670-71, 632 A.2d 1353, 1356 (1993), appeal denied, 538 Pa. 618, 645 A.2d 1321 (1994). Accord Black's Law Dictionary 104 (6th ed., reprinted 1993). An opponent also can be deemed to have brought suit "vexatiously" if he filed

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