Record Below Did Not Show The Trial Judge Imposed It In Retribution Against Ex-Husband.
In Marriage of Ward, Case No. A156599 (1st Dist., Div. 5 Apr. 29, 2020) (unpublished), ex-husband appealed a $24,000 needs-based fee award under Family Code sections 2020/2032. His only challenge on appeal was that the lower court imposed this award in “retribution” for him raising certain spousal support issues (issues which, by the way, had to be considered when making the needs-based award). The appellate court affirmed, and for a simple reason: the statement of decision did not bear out at all that the award was done for retribution.
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