Lack Of Express Findings On The Factors Required A Remand.
In In re Marriage of Patton, Case No. B329509 et al. (2d Dist., Div. 4 Aug. 29, 2024) (unpublished), the appellate court reversed a family law judge’s failure to award Family Code section 2030 fees to ex-wife, where the record showed she made $60,000 a year versus $500,000 a year for ex-husband, and she had no savings versus ex-husband receiving $2 million from the sale of stock options. The lower court failed to make express findings on the section 2030(a)(2) factors, much less weighed the reasonableness of ex-wife’s fee request. This was an abuse of discretion leading to a remand to award some amount of reasonable fees to ex-wife.