Different Result Had Sanctions Been Imposed On Both Client And Attorney
The probate court in In re Patrice Libaw Trust, Case No. B271815 (2d Dist., Div. 1 Aug. 3, 2017) (unpublished) awarded CCP § 128.7 sanctions against only a probate litigant’s attorneys, not the probate litigant (although sanctions were requested against both). Litigant appealed the sanctions award against attorneys, but the appellate court determined it lacked jurisdiction because client alone did not have standing to appeal an adverse award against her attorneys. The result would have been different had both client and attorneys been assessed with sanctions; however, this did not happen, so no appellate jurisdiction.