Settlement ≠ Open Tab For Attorney-fees

Kansas Court of Appeals (Gould v. Crawley, July 2025) just reminded us:

 • A broad release (“all claims … arising out of the action”) sweeps in law-firm fee requests—even ones based on discovery fights.
 • Courts keep jurisdiction to award fees after a case is dismissed, but only if the settlement leaves that door open.
 • No carve-out = no post-deal fee motion. 

Practical tip: When you draft a settlement, spell out whether sanctions / Rule 11 / discovery-cost claims survive. Otherwise, they’re gone the moment the dismissal hits the docket.