No Particular Order Wording Needed to Show Relevant Financial Factors Weighed.
The lesson in Marriage of Walter, Case No. B225762 (2d Dist., Div. 6 June 2, 2011) (unpublished) is not that spectacular as far as results: the appellate court affirmed a needs-based attorney’s fees award of $3,250 under Family Code section 2030 in favor of wife when husband dismissed a count and had other counts in a multi-count contempt OSC adjudged against him–an exercise making a needy wife miss multiple days of work.
Husband argued on appeal that the lower court failed to make mention of any facts or findings related to the needs-based factors having to be considered under section 2030. Not so, said the reviewing court. “But no particular language is required in the order,” with the record simply needing to establish that the lower court properly considered the statutory factors (which it did). See, e.g., Alan S. v. Superior Court, 172 Cal.App.4th 238, 254 (2009).