Bad Litigation Tactics Alone Will Not Support 2030/2032 Award.
Although the $5,000 fee award to husband may seem paltry based on the needs-based anchors of Family Code section 2030/2032, it was reversed in Marriage of Overstreet, Case No. B271522 (2d Dist., Div. 1 Mar. 28, 2017) (unpublished). The reason is that the family law judge did not consider all of the 2030/2032 factors, focusing myopically only on the litigation tactics of the other side. This alone will not justify such a needs-based fee award.