Gotta Have Causation, Family Law Practitioners!
Okay, we have posted before on sanctions awarded against litigants in a family law dissolution or related matter under Family Code section 271, which is aimed at dissuading conduct which is frivolous or not targeted at resolving the matter. The facts in Marriage of Karuppiah and Thurairajah, Case No. D071601 (4th Dist., Div. 1 Oct. 31, 2018) (unpublished) are not important because a $10,000 section 271 sanctions award was vacated. The problem was that the winning litigant must “tether” the request to attorney’s fees and costs actually incurred—a causation principle. Because that was not done in this case, the $10,000 award was invalid.