Reversal As A Matter Of Law Was The Result.
Ex-husband’s attorney in Forrest v. Forrest, Case No. D086281 (4th Dist., Div. 1 July 8, 2026) (unpublished) had a $5,000 monetary sanction imposed for certain conduct in a marital dissolution case, exclusively assessed under Family Code section 271. That sanction order was reversed as a matter of law because section 271 does not authorize sanctions against a litigant’s attorney. (Featherstone v. Martinez, 86 Cal.App.5th 775, 784 (2022); accord, Burkle v. Burkle, 144 Cal.App.4th 387, 403 n. 7 (2006); Orange County Dept. of Child Support Services v. Superior Court, 129 Cal.App.4th 798, 804 (2005); In re Marriage of Daniels, 19 Cal.App.4th 1102, 1110 (1993) [predecessor statute]; Koehler v. Superior Court, 181 Cal.App.4th 1153, 1164 n. 5 (2010).)