Family Law: Needs-Based/Sanction Fee Awards To Wife Were Correct

 

Appellant Failed to Provide Fair Statement of Evidence or Support Argument With Proper Analysis.

     Marriage of McIntyre and Shayan, Case No. B229106 (2d Dist., Div. 8 Jan. 6, 2012) (unpublished), although involving a pro per appellant husband losing a needs-based/sanctions fee award to wife, does reinforce certain principles that every appellant needs to follow on appeal. His contentions of error were forfeited because he did not do these things: (1) failing to provide a fair summary of the evidence (Nwosu v. Uba, 122 Cal.App.4th 1229, 1246 (2004)--an important decision on this point); (2) failing to provide citations to the record in support of arguments (Cal. Rules of Court, rule 8.204(a)); and (3) failing to provide an adequate record of lower court proceedings (Wagner v. Wagner, 162 Cal.App.4th 249, 259 (2008)). However, even on the merits, the limited record showed wife was on government assistance and husband had financial means not identified in his income/expense statements, reason enough to sustain the fee awards. Good guide to appellate fundamental primer points in this specialized practice area, we might say.