Trial Transcript Records Are Key In This Area.
In Marriage of Jensen, Case No. H04948 (6th Dist. Aug. 17, 2022) (unpublished), we picked up on these takeaways: (1) Family Code section 271 sanctions need to be timely requested during family law proceedings; and (2) Family Code section 2030 “needs” based awards need to comply with a three-prong express finding statutory requirement. In this situation, the lower court did not properly indicate why ex-husband could not afford both parties’ fees—the third prong—so that the matter was reversed. It was unclear whether it was outright reversed or remanded.