Cannot Bootstrap and Avoid of Finality of Sanctions Order, Says Appelllate Court.
In Wang v. Cunningham, Case No. A134757 (1st Dist., Div. 2 Jan. 31, 2013) (unpublished), a family law judge refused to reverse an earlier 2010 order awarding Family Code section 271 sanctions of over $32,000 to a former wife, doing so through a 2012 judgment “confirming” the earlier award. Husband then attempted to challenge the 2010 sanctions order through an appeal of the 2012 judgment, even though the sanctions order was long since final. Nice try, said the appellate court, but you cannot bootstrap an appeal of the 2012 “confirmation” order into an appeal of the long-ago final 2010 sanctions order. Appeal dismissed.