Lack Of Family Code Section 2030 Findings Constituted An Abuse Of Discretion.
In Marriage of Tran and Ha, Case No. G064047 (4th Dist., Div. 3 Feb. 17, 2026) (unpublished), ex-wife’s requests for two sets of fees (which were denied) did not result in a relook on appeal, but her request for non-appellate, needs-based fees had to be reversed and remanded based on a failure to make Family Code section 2030 required findings.
Her appellate fees were properly denied because she failed to timely request them within 40 days after the remittitur issuance. (CRC 3.1702(c)(1).) The appellate court determined this deadline did apply to family law cases. (CRC 3.10; CRC 5.2(d); In re Marriage of Freeman, 132 Cal.App.4th 1, 4, 9 (2005).)
The fees under a Marital Settlement Agreement were properly denied because she did not show the work fell within the scope of the contractual fees clause or that she gave a 10-day default notice to ex-husband.
However, the needs-based fee denial for non-appellate work was reversed, because the lower court’s summary denial did not make the Family Code section 2030 findings on disparity and need, so that was remanded for a re-examination.