They Did Not Exceed The $5,000 Threshold Under CCP § 904.1(a)(12), And They Cannot Be Aggregated With Prior Sanctions To Reach The Appealable Threshold.
Lin v. Chao, Case No. H052699 (6th Dist. Oct. 16, 2025) (unpublished) found that an appeal of a Family Code section 271 sanctions award of $5,000 was not appealable under CCP § 904.1(a)(12), because it did not exceed $5,000. Appellant tried to argue that the sanctions amount was appealable because it had to be aggregated with prior sanctions awards coming to $45,000, but that argument was found to lack merit based on Calhoun v. Vallejo City Unified School Dist., 20 Cal.App.4th 39, 44-45 (1993), disapproved on other grounds in K.J. v. L.A. Unified School Dist., 8 Cal.5th 875, 888 n. 6 (2020).