Appeal Was Premature.
In Marriage of Garcia, Case No. B231782 (2d Dist., Div. 3 June 1, 2012) (unpublished), ex-wife appealed from a $1,000 “sanctions” order under Family Code section 2107(c), which does allow for imposition of attorney’s fees for a family law litigant not complying with family law provisions. (Apparently, she failed to produce a preliminary declaration of disclosure and was “sanctioned”.)
Wife’s appeal from the sanctions order was dismissed as premature. CCP § 904.1(b) does provide that sanctions under $5,000 can only be reviewed through an appeal of the final judgment (or, even less successfully, through an extraordinary writ, which was not done). Given the concession on appeal that no final judgment had been reached, the sanctions order appeal had to be dismissed.