$3,750 Sanctions Award Against Counsel Violated Due Process Standards.
The Second District, Division 6, in North County Watch v. County of San Luis Obispo, Case No. B231090 (2d Dist., Div. 6 Mar. 27, 2012) (unpublished), reversed imposition of a $3,750 sanctions award on counsel for failure to comply with court rules for prosecution of a CEQA petition on behalf of a client. (You land use practitioners out there know there are very different and expedited procedures applicable to CEQA matters.) Basically, CEQA claimant missed a court ordered deadline for filing its trial brief, resulting in the sanctions against its attorney. The reversal of the sanctions award against counsel was required because the opponent’s motion for sanctions did not indicate the target was the attorney, referencing only attorney’s client, and because the actual sanctions motion admitted that the sanctionable conduct was not attributable to counsel. Due process prevailed, resulting in an overturning of the sanctions against attorney.