Judgment Enforcement: Judgment Creditor Entitled To Contempt Attorney’s Fees And Costs Against Person In Post-Judgment Enforcement Proceeding, Even Though That Person Was Not A Litigant In The Underlying Lawsuit

CCP § 1218 Was The Governing Statute Allowing For This Result. 

               In Ofek Rachel, Ltd. v. Zion, Case No. B333959 (2d Dist., Div. 2 Nov. 21, 2024) (published), a person who was not a litigant in an underlying lawsuit was found guilty of contempt in post-judgment enforcement proceedings, ordered to pay the judgment creditor $185,695.20 in attorney’s fees and $8,964.71 in costs under CCP § 1218(a).  The 2/2 DCA affirmed, concluding that the post-judgment enforcement proceeding was a separate action which allowed the award against a person who was not a litigant in the underlying suit.