Appellate Court Could Not Discern Basis For The Substantial Reduction, So Remanded.
In Costa v. Kral, Case No. G065336 (4th Dist., Div. 3 June 29, 2026) (unpublished), there was no dispute that a civil harassment restraining order litigant prevailed and was entitled to fees under CCP § 527.6(s). Winning litigant moved for $21,237.50 in prevailing party fees, but the trial court awarded $4,500 with no explanation—even though the other side did lodge multiple objections for reductions. The over 75% reduction was found to be an abuse of discretion because the 4/3 DCA, in an opinion authored by Justice Delaney, was troubled as to whether the reduction was based on the hours charged or the hourly rate. It simply remanded for a clearer explanation of the eventual fee award crafted by the lower court.