Sixth District Follows First District’s Lead As Far As Section 271 Sanctions Limitations.
In Marriage of Henley & Jackson, Case No. H043753 (6th Dist. June 29, 2018) (unpublished), a family law judge imposed Family Code section 271 sanctions of $25,000 against husband for his efforts to sell a community asset without notice to wife, even though she incurred no attorney’s fees and costs in the process. That, among other issues, were reversed and remanded on appeal, by husband. The Sixth District adopted the reasoning of the First District in Sagonowsky v. Kekoa, 6 Cal.App.5th 1142, 1144, 1157 (2016), which held that misconduct over beyond fees/costs actually incurred was not within the reach of section 271.