No Huge Dispute, But Appellate Court Only Awarded Sanctions For Direct Expenses Relating To the FSC Violation.
Steele v. Paulee Body Shop, Inc., Case No. B344258 (2d Dist., Div. 3 Jan. 30, 2026) (unpublished) shows how a sanctions request needs to be calibrated to expenses incurred on the actual violation, not ancillary expenses which are claimed by the prevailing party.
There, it was undisputed a party missed an initial Final Status Conference appearance. If the expenses for that were considered, they totaled $2,430. However, the other side claimed more, $13,770—which was awarded—for certain subsidiary costs. The 2/3 DA reversed and reduced the sanctions to $2,430. It found non-compensable these items not directly tethered for the missed FSC violation: (1) costs incurred to file joint trial documents which were timely filed and agreed to by the offending party; and (2) certain subsequent normal course litigation appearances stemming from the on-going litigation. So, to be clear, the $2,430 was awarded as sanctions and the matter was put to an end by the DCA—with no appellate costs awarded to either side.