Deadlines: Special Deadlines Govern Appeal Of Costs Orders In Validation Actions, With Appellants Being Untimely

Special Attention Needs To Be Paid In Validation Proceedings—Appeal Deadlines Are Different.

            Validation proceedings have their own time deadlines, including times to appeal.  In County of Alameda v. Alameda County Taxpayers Assn., Case No. A167040 et al. (1^st Dist., Div. 5 Jan. 29, 2024) (unpublished), a litigant appealed a postjudgment costs order in a validation proceeding, appealing 59 days after service of the costs order.  That was untimely, with the appeal dismissed because this order had to be appealed 30 days later, not 59 days later.  (CCP § 870(b); Planning & Conservation League V. Dept. of Water Resources, 17 Cal.4^th 264, 266-267 (1998).)  That same rule, the shorter 30-day rule, applies to filing for an attorney’s fees motion in a validation proceeding.  (Central Delta Water Agency v. Dept. of Water Resources, 69 Cal.App.5^th 170, 212-213 (2021).)