Does a plaintiff have an absolute right to dismiss their action?

Plaintiffs ignore that they do not have an absolute right to the voluntary dismissal of their action. (Zapanta v. Universal Care, Inc. (2003) 107 Cal.App.4th 1167, 1171.) A plaintiff has a right to dismiss prior to trial, but not after commencement of trial. Section 581, subdivision (a)(6) defines the commencement of trial as "the beginning of the opening statement or argument of any party or his or her counsel, or if there is no opening statement, then at the time of the administering of the oath or affirmation to the first witness, or the introduction of any evidence."