None Of The Claimed Bases Justified A Fees Award.
In City of Grass Valley v. Coulter, Case No. C102046 (3d Dist. Sept. 19, 2025) (unpublished), City obtained a workplace restraining order against Coulter under CCP section 527.8, subsequently later obtaining a contempt order against Coulter for violating the restraining order. The contempt order was annulled by the lower court after the appellant court expressed an inclination to issue a writ in Coulter’s favor. Coulter’s subsequent request for an award of attorney’s fees under various statutory bases was denied by the lower court.
The Third District affirmed, deciding as follows: (1) section 527.6 did not allow for fees because a contempt proceeding was involved; (2) Government Code section 27706 did not provide a basis for fee entitlement; (3) the public attorney general statute did not justify fees because Coulter did not obtain benefit for a significant number of persons versus his personal interest; and (4) CCP section 1218, the contempt statute, did not allow for fees to litigants successfully defending against a contempt proceeding.