Perow v. Uzelac (In re Perow)

*986When a party to a dissolution proceeding moves to modify an existing order, the other party may ask the court for "affirmative relief" in a responsive pleading, but only if that relief is "alternative to that requested by the moving party" and "on the same issues raised by the moving party." ( Fam. Code, § 213, subd. (a).)1 Is a responding party's request for sanction-based attorney fees under section 271 a request for "affirmative *987relief"? We conclude that it is not. Accordingly, and because the appealing party's other challenge lacks merit, we affirm the award of sanctions in the form of…