Statutory Language Allows Both To Be Imposed.
The family law judge in Marriage of O’Connell, Case No. G047362 (4th Dist., Div. 3 Apr. 22, 2014) (unpublished) imposed $62,903 in sanctions as well as awarded one-half of undisclosed financial accounts in favor of wife and against husband under Family Code section 1101(g). Husband argued this was “double-dipping,” but the appellate court disagreed because the statutory language indicated that the court penalty “include[d], but was not limited to” this remedy. This “not limited to” language demonstrated the family judge could go farther by awarding sanctions on top, as the lower court properly did in the case before it. Justice Ikola authored this decision.