Multiple Bases Supported Sanctions Award.
You gotta really look at the facts when appealing a discretionary sanctions award. If they bad, you might want to forego and go onto more productive ventures. Archer v. Archer, Case No. B254750 (2d Dist., Div. 4 Jan. 26, 2015) (unpublished) teaches that well.
This one involved a dispute between brothers over several real estate parcels jointly owned by them, with brother John getting the better of it in an arbitration against brother Jeff. Jeff apparently then attempted to avoid enforcement of the arbitration awards, forcing John to get a bankruptcy lift stay order and trying to only enforce selective portions in Jeff’s favor—even though John clearly had net judgments in his favor. That provoked "dueling" 128.7 motions by both brothers. John won, and Jeff lost. The trial court awarded John $9,999.99 in sanctions against Jeff and his attorney.
The orders were affirmed. Although a frivolous argument ground for sanctions is usually only levied against the attorney, here the trial judge found that other sections based on misrepresentations, omissions, and repeated attempts to avoid enforcement of the arbitration award presented independent grounds justifying sanctions under 128.7 against both client and his attorney.