What is the test for voluntary dismissal of an action by a party who has followed the action through to completion?

^3. This voluntary dismissal qualifies as an action "finally determined adversely to the person," within the meaning of section 391, subdivision (b)(1). (Tokerud v. CapitolBank Sacramento (1995) 38 Cal.App.4th 775, 779 ["An action which is ultimately dismissed by the plaintiff, with or without prejudice, is nevertheless a burden on the target of the litigation and the judicial system, albeit less of a burden than if the matter had proceeded to trial. A party who repeatedly files baseless actions only to dismiss them is no less vexatious than the party who follows the actions through to completion. The difference is one of degree, not kind"].)