In State ex rel. Hummel v. Sadler (2002), 96 Ohio St.3d 84, 88, 2002 Ohio 3605, 771 N.E.2d 853, the Ohio Supreme Court held that "despite a voluntary dismissal under Civ.R. 41(A)(1), a trial court may consider certain collateral issues not related to the merits of the action." Sanctioning a party for frivolous conduct is considered a collateral proceeding, and trial courts retain jurisdiction to make this determination under R.C. 2323.51 subsequent to a case being voluntarily dismissed. See Dyson v. Adrenaline Dreams Adventures (2001), 143 Ohio App.3d 69, 72, 757 N.E.2d 401.