Deferential Abuse of Discretion Standard Sealed the Deal.
In Marriage of Browne, Case No. A139607 (1st Dist., Div. 5 May 27, 2014) (unpublished), ex-husband got hit with a $3,000 Family Code section 271 sanctions for filing “too many motions” against ex-wife. That determination was affirmed on appeal. Although the written order did not say so, the oral hearing transcript specified this was the basis, and the record supported it—especially under the deferential abuse of discretion standard.