Sanctions Do Not Need A Precise Correlation To Sanctioned Conduct And The Specific Fees.
In Lebid-Jurtschyk v. Lebid-Jurtschyk, Case No. B300370 (2d Dist., Div. 4 June 25, 2020) (unpublished), ex-husband was hit with Family Code section 271 sanctions for insisting on too high of a listing price for a house, not signing documents to get the deal done, and not contributing to repairs on the house. Ex-husband’s appeal was not successful, given the facts showed he was not cooperative in trying to settle the divorce issues. With respect to the argument that some related time was not compensable, the appellate court indicated that section 271 does not require a precise correlation between the sanctioned conduct and the fee award, a determination affirmed on appeal. (In re Marriage of Corona, 172 Cal.App.4th 1205, 1226 (2009).)