The Statutes Serves Separate Policy Purposes, Such That They Can Be Concurrently Applied In Dissolution Proceedings.
Arora v. Arora, Case No. D086321 (4th Dist., Div. 1 Sept. 28, 2026) (unpublished) involved a clash between two schemes, contempt proceedings and Family Code section 271 sanctions, with ex-wife arguing that that her failure to prevail in earlier contempt proceedings somehow inhibited section 271 sanctions. The lower and appellate courts disagreed. Family Code sanctions provisions and contempt proceedings serve different public policy purposes, so they can be concurrently applied in furtherance of doing justice. The order dismissing ex-wife’s contempt proceeding did not impede the award of section 271 sanctions despite wife’s argument that only she could obtain contempt fees under CCP § 1218(a). Entirely different purposes were served by the two schemes, such that the section 271 sanctions award of $50,00 in favor of ex-husband was affirmed.