First Aftermath of Published Rickley v. Goodfriend Decision
On July 30, 2012, we posted on Rickley v. Goodfriend, 207 Cal.App.4th 1528 (2012) (Rickley I), which reversed a fee denial reversed, based on CCP § 1218 which does allow contempt proceeding fee-shifting in the right circumstances. The matter was remanded, however, to determine if there was an attorney-client relationship between attorney and homeowners (given that attorney was one of the co-plaintiff homeowners)–making sure that attorney was outside of the Trope v. Katz in pro per prohibition.
Recently, the same appellate court remanded one of the fee denials in trial court proceedings based on Rickley I. Although the opinion is really just a remand and breaks no new ground, here is the slip opinion information for your reading pleasure: Rickley v. Goodfriend, Case No. B238965 (2d Dist., Div. 7 Oct. 15, 2012) (unpublished). (Rickley II).