The defendant objected to the voluntary dismissal of the case but the motion was granted over the defendant's objections. The Appellate Court reasoned that as the plaintiff had the absolute right to voluntarily dismiss a case, the motivation of a plaintiff's attorney, even if it was solely to avoid sanctions, was irrelevant. Seizing on this provision, the defendant in Wright argued that even if the plaintiff was entitled to voluntarily dismiss, the dismissal should be conditioned on the plaintiff's agreement to be bound by previous discovery orders. The Appellate Court declined to condition voluntary dismissal on the plaintiff's agreement to be bound. Although the plaintiff in Wright may have won the battle with regard refiling his case, it is far from clear that the plaintiff won the war.
Courts have discretion to subject parties to discovery sanctions following a voluntary dismissal.
So, it is entirely possible that the plaintiff still faced trial without his experts. Nonetheless, the Wright court held firm to the proposition that sanctions do not automatically follow the plaintiff and so plaintiffs may still file voluntary dismissals hoping to find a more sympathetic ear.