Family Law: $30,000 271 Sanctions Against Ex-Husband Not Reviewable For Lack Of Adequate Record Including Family Hearings Which Led To The Sanctions Order

Also, Disentitlement Doctrine Might Prevent Further Appeals By Ex-Husband.

            Ex-husband in Marriage of Volovik & Parchin, Case No. B280980 (2d Dist., Div. 5 Apr. 18, 2018) (unpublished) was disgruntled when the lower court imposed a Family Code section 271 sanction award of $30,000 against him, although the result could have been worse given the 271 request for $70,964.  The sanctions order was affirmed because ex-husband failed to provide an adequate record in the form of reporter’s transcripts of family law hearings which would have allowed the appellate court to see if there was a true abuse of discretion.

            The appellate court, in a footnote, also indicated that it might not entertain future appeals by ex-husband under the disentitlement doctrine.   It was alleged that ex-husband only paid $197 of the $30,000 sanctions award, such that the reviewing court can dismiss an appeal for a litigant’s failure to comply with trial court orders, in this case the $30,000 sanctions order which was sustained after this particular appeal.