C.A. 2nd;
B269311

The Second Appellate District reversed a family court order. The court held that the family court was without authority to award sanctions to a party's former attorneys for the sole benefit of the attorneys.

During the course of dissolution proceedings, Deborah Webb recorded family law attorney real property liens in favor of attorney Patrick DeCarolis and his law firm, Trope and DeCarolis, and attorney Sandra Polin. Husband William Webb's objections to the liens were unavailing. Five months later, In December 2012, William and Deborah both separately applied to the court to expunge the liens. The court denied the applications. Subsequent requests were similarly unavailing. A judgment of dissolution was entered in 2014. When disputes over the liens continued, DeCarolis and Polin moved for sanctions against William under Family Code §271. They sought sanctions in the amount of $86,565 for their time spent responding to William's challenges to the liens.