Due Process Was the Reason for Reversal.
Marriage of Kleytman and Pechonkina, Case No. A134740 (1st Dist., Div. 2 July 18, 2013) (unpublished) is a good illustration of how due process can prevail in a family law sanctions context.
Here, husband was sanctioned under Family Code section 271 for $2,500 in fees both for conduct at a specified hearing and “unspecified” conduct “in connection with previous several motions.” The fee sanctions award was reversed, because the last component of unspecified conduct did not provide proper notice of the sanctions target. Reversed and remanded for a re-do.