Gotta Develop an Adequate Record, Appellate Law 101.
Castruita v. Guerrero, Case No. B246439 (2d Dist., Div. 7 Feb. 24, 2014) (unpublished) is a situation where a party moving for a temporary restraining order and permanent injunction against his uncle lost and was ordered to pay uncle’s counsel at the time $1,000 in fees.
The appellate court affirmed the fee award based on an Appellate Law 101 principle: you must develop an adequate record to overcome the presumption that a trial court ruling below is correct. Here, appellant failed to file a reporter’s transcript of the hearing and only included his moving papers, which retarded the ability to hurdle the presumption of correctness. (Appellant did try to dodge the lack of a reporter’s transcript by indicating that budgetary restraints had made a reporter impossible to get; however, remember you can bring your own if you follow the correct protocol.)