SLAPP: SLAPP Fee Order Appealable Under Collateral Order Exception

However, Fee Order Affirmed Due To Inadequate Record.

     In Van v. Cameron, Case No. D068630 (4th Dist., Div. 1 July 14, 2013) (unpublished), plaintiff lost a SLAPP motion and was hit with a mandatory fee award of $24,815.75.   Plaintiff’s appeal was unsuccessful on the merits.  Although the defense raised the argument that the SLAPP fee order was not appealable per se, the appellate court agreed it was reviewable under the collateral order exception.  (City of Colton v. Singletary, 206 Cal.App.4th 751, 781 (2012).)  However, after surmounting the appellate jurisdictional hurdle, plaintiff lost on the merits—no attorney’s fees motion was presented in the record, so there was an inadequate record to review the issue.  Affirmed.