This next decision reminds all appealing parties to make sure you hit all arguments, especially independent bases for a fee award. Failure to address an alternative predicate for a fee award can be fatal, as it was here.
Ex-wife in Marriage of Rica, Case No. A135687 (1st Dist., Div. 5 Apr. 30, 2013) (unpublished) won in the lower court an increase in child support obligations, with the trial court also awarding her over $41,000 in feees/costs under either Family Code section 2030 (needs-based statute) or section 271 (sanctions-based statute).
On appeal, ex-wife lost the child support modification, which might have impacted her fees/cost award under section 2030. However, ex-husband failed to contest the section 271 fees/costs basis …… and, you guessed it, that means the award was affirmed on appeal. Lesson learned the hard way.
Mind your lesson Fido. Currier & Ives. Between 1856 and 1907. Library of Congress.