Inadequate Appellate Record Required Affirmance – “A Little Learning Is A Dangerous Thing”.1
Marriage of Hettinga & Loumena, Case No. H041589 (6th Dist. Nov. 22, 2016) (unpublished) shows the dangers of undertaking an appeal without knowing the nuances of appellate practice. In this one, wife—who previously had been sanctioned $100,000 and declared a vexatious litigant—got sanctioned against for $210,000 under Family Code section 271. Although she appealed, the award was affirmed because an inadequate record was presented before the reviewing court: incomplete sanction motion paperwork was presented and no record citations to hearing transcripts were included. Ouch!
______________________________1 “A little learning is a dangerous thing;
Drink deep, or taste not the Pierian spring.” — Alexander Pope, Part II of An Essay on Criticism. Often misquoted as, “a little knowledge is a dangerous thing.”