Appealabilty, Costs: Only Adding Costs To A Judgment, Through An Amendment, Does Not Rest Time To Appeal From The Original Judgment

No Substantial Modification Was Obtained By Adding Costs To A Judgment.

            In Crokin v. Primrose, Case No. G061959 (4^th Dist., Div. 3 Jan. 3, 2024) (unpublished), authored by Presiding Justice O’Leary, the 4/3 DCA agreed that adding routine costs, attorney’s fees, and interest to an original judgment through an amended judgment did not reset the time to appeal from the original judgment because the changes were not substantial.  The costs award was separately appealable, such that it should have been separately appealed.  (Torres v. City of San Diego, 154 Cal.App.4^th 214, 222 (2007); Dakota Payphone, LLC v. Alcaraz, 192 Cal.App.4^th 493, 504-505 (2011).)