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Family,
California Courts of Appeal

Dec. 2, 2015

Ruling dishes on Family Code fee awards

A recent appellate ruling wrestled with whether a trial court must differentiate between fee awards under the cost-shifting provisions of the Family Code and awards under the sanctions section.

Claudia Ribet

Of Counsel
California Appellate Law Group LLP

appellate law (certified) and family law (certified)

811 Wilshire Blvd 17th Floor
Los Angeles , California 90017

Phone: (213) 878-0404

Antioch School of Law

California Appellate Law Group LLP is an appellate boutique with offices in San Francisco and Los Angeles. Claudia is one of only three attorneys in California certified by the State Bar as a specialist in both family law and appellate law. Find out more about Claudia and the California Appellate Law Group LLP at www.calapplaw.com. Appellate Zealots is a monthly column on recent appellate decisions and appellate issues written by the attorneys of the California Appellate Law Group LLP.

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In the case of In re Marriage of Smith, 2015 DJDAR 12581 (Nov. 20, 2015), the 4th District Court of Appeal decided whether a trial court must make an explicit differentiation between the attorney fees sums awarded pursuant to the family law cost-shifting provision (Family Code Section 2030) with those awarded under the sanctions section (Family Code Section 271). The answer to that question is no, at least on the facts presented in this case.

The court also decided whether, i...

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