June 11, 2026
Court of Appeal of the State of California, First Appellate District, Division Three
The Rule of County of Del Norte v. Britt is that a responding party who prevails in a receivership proceeding under Health and Safety Code section 17980.7(c) is entitled to attorney fees and court costs under section 17980.7(c)(11), even against a municipal enforcement agency, because this more recent and specific statute creates an exception to the general rule of section 17984 that shields public agencies from cost liability, under circumstances where the responding party was improperly named as a defendant and achieved complete vindication on the claims against them.
April 3, 2026
Court of Appeal, Second Appellate District, Division Six
The Rule of In re Marriage of Charles and Julie Ann Bowman is that trial courts retain discretion to consider Family Code factors including the losing party's ability to pay when determining the amount of attorney's fees under a prevailing party clause in a marital settlement agreement, under circumstances where the MSA contains a general attorney's fees provision without specific limitations on the court's consideration of equitable factors.