Laches Ruling Needed To Be Revisited.
In Marriage of Goldman, Case No. D082021 (4th Dist., Div. 1 Jan. 10, 2025) (partially published; fee discussion unpublished), ex-husband and ex-wife entered into a marital settlement agreement (MSA) which wife claimed was breached and then asked for needs-based fees and costs to enforce it. The lower court determined that ex-wife’s efforts were barred by laches. Although the appellate court determined that the laches defense was available with respect to the MSA under Family Code section 291, it found that the laches defense was not supported by substantial evidence and remanded for a revisit. As a result, the needs-based attorney’s fees and costs request—which was denied—also had to be looked at again.