Family Law: $10,000 Needs-Based Fee Award To Wife Reversed Because Family Court Failed To Make Mandatory Findings Required Under Family Code Sections 2030/2032

Fifth District’s Morton Decision Found Persuasive To The 4/1 DCA.

            The Fourth District, Division 1 in Marriage of Bustillo, Case No. D075369 (4^th Dist., Div. 1 Sept. 12, 2019) (unpublished) reversed a $10,000 “needs-based” fee award to ex-wife under Family Code section 2030 and 2032 for a multiday support hearing.  The reason was that the family law judge failed to make mandatory findings for needs-based awards as detailed in In re Marriage of Morton, 27 Cal.App.5^th 1025, 1049-1054 (2018), a Fifth District decision which the 4/1 DCA found to be well-reasoned and persuasive.  Morton is must reading for family law practitioners, in our view, when asking for pendente lite fee awards of this nature.