City & County of San Francisco v. Price, Case No. A139024 (1st Dist., Div. 2 Mar. 29, 2016) (Unpublished).
Wife challenged a $1,200 sanctions award presumably made under Family Code section 271 after husband made the request orally at a hearing. She argued this was a due process violation, but the appellate court found no form of notice is specified under section 271 and that opportunity to be heard at a hearing suffices where the amount requested is small in amount. She was given an opportunity to be heard through counsel, which was enough. With respect to the contention the lower court did not consider her ability to pay, the record showed the judge did stretch payment of the sanctions over 6 months—showing consideration for her fixed income situation.
Marriage of Patel, Case No. B257700 (2d Dist., Div. 3 Mar. 29, 2016) (Unpublished).
A section 271 sanctions award against husband for $20,000 was affirmed because there no minute orders being appealed from and the parties stipulated to orders resolving certain payment issues (inclusive of fees) such that the controversy was moot on appeal.