Cases: Family Law

  Marriage of Rice and Eaton, No. C066860 (3d Dist. Apr. 4, 2012) (partially published; 271 discussion unpublished).      Although the published part is an interesting discussion of the impact of Department of Child Support Services contempt proceedings on wife’s OSC to obtain enforcement of delinquent child support payments, the unpublished part relating to fees […]

Marriage of Csupo, Case No. B227959 (2d Dist., Div. 1 Mar. 27, 2012) (unpub).      In this one, the trial court terminated the husband’s obligation to continue paying attorney’s fees under a pendente lite order, a determination affirmed on appeal after husband paid $30,000 under the earlier $180,000 fee mandate, after wife apparently fired

  Failure to Specify Statutory Basis For Fee Award Was Not Reversible Error.      Husband in Marriage of Fong, Case No. B233513 (2d Dist., Div. 3) (unpublished) got hit with a $180,000 adverse award of attorney’s fees in favor of wife under various Family Code sections based on need or sanctioning authority–areas we have discussed

  “Big” Picture Was Considered By Family Judge, Especially Where Husband Had Substantial Assets And Outspent Wife By Almost Double In Dissolution Fees.      As we predicted in our post of March 21, 2009, family law practitioners would use “big” picture language from Alan S. v. Superior Court, 172 Cal.App.4th 238 (2009) in arguing that

  Appellant Failed to Provide Fair Statement of Evidence or Support Argument With Proper Analysis.      Marriage of McIntyre and Shayan, Case No. B229106 (2d Dist., Div. 8 Jan. 6, 2012) (unpublished), although involving a pro per appellant husband losing a needs-based/sanctions fee award to wife, does reinforce certain principles that every appellant needs to

  Court of Appeal Determines Scope of Section 2102(c) and Reminds Practitioners That Section 2030/2032 Fees Are Based on Relative Needs Even With High Net Worth Spouses.      Marriage of Sorge, Case Nos. D57677/58611 (4th Dist., Div. 1 Jan. 5, 2012) (certified for publication) reversed a Family Code section 2102(c) breach of fiduciary duty sanctions

  No Statement of Decision Required For Dissolution Fee Matters At the Time.      Marriage of Carson, Case No. E052074 (4th Dist., Div. 2 Jan. 4, 2012) (unpublished) involved a husband who appealed orders requiring him to pay attorney’s fees to his wife under Family Code sections 271 (sanctions statute, for not fostering settlement) and

Marriage of Bader, Case No. G044876 (4th Dist., Div. 3 Dec. 21, 2011) (Unpublished).      In this one, husband appealed a $20,000 needs-based attorney's fees award to wife (out of a requested $25,000) under Family Code sections 2030/2032. Husband claimed that the award had to be reversed because no express findings were made on