Family Law, Sanctions: $73,000 Fee Award, $220,952 Expert Fee Award, And $200,000 Sanctions Award Under Family Code Section 2107(c) Were Not Erroneous

Statutory Provision Allows For These Awards Where An Ex-Spouse/Ex-Partner Fails To Satisfy His/Her Disclosure Violations In A Dissolution Proceeding.

            Family Code section 2107(c) allows a family law judge to award fees, costs, and sanctions for disclosure violations during a dissolution proceeding, with certain disclosure obligations triggered by the service of the divorce action.  In Marriage of Matkovic, Case No. H047406 (6^th Dist. Nov. 14, 2022) (unpublished), ex-wife was hit with $73,000 in attorney’s fees, $220,952 in expert costs, and $200,000 in deterrence sanctions under section 2107(c).  Although hefty, the Sixth District found the awards were no abuse of discretion by the lower court.  The appellate court affirmed these rulings, but it did remand for a reduction in an award under Family Code section 1101(g) [limiting misappropriation awards to an ex-spouse’s community interest in an undisclosed or transferred asset].