Equity: Appellate Court Summarily Reverses Fee Grant Order After Referee’s Merits Decision Reversed

Court Of Appeal Decided It Had Independent Authority To Summarily Reverse Despite Clear Statutory Authority To Do So.

               In Hot Rods, LLC v. Northrop Grumman Systems Corp., Case No. G062524 (4^th Dist., Div. 3 May 8, 2024) (unpublished by-the-court opinion), a referee’s prior merits decision was reversed and remanded, with the aggrieved party also appealing from a subsequent postjudgment fees award.  Although it was unclear whether the stipulated reversal procedure in CCP § 128(a)(8) applied to appeals or whether the presumption against stipulated reversals applies to a postjudgment fees order, the appellate court found it had inherent authority to issue a summary reversal where, as here, the reversal of the fee order was clear and public trust issues were not implicated.