20th Century Insurance v. Tak Hung Choong

Opinion

JOHNSON, J.

In this case we hold an attorney-employer has standing to appeal a monetary sanction imposed on an attorney-employee. We also hold imposing a monetary sanction for not paying a previous monetary sanction was not an abuse of discretion.

Facts and Proceedings Below

At a mandatory settlement conference, the trial court imposed a sanction in the amount of $200 on plaintiff’s attorney, Richard Collins, for failure to prepare a mandatory settlement conference statement. (Super. Ct. L.A. County, Local Rules, rule 7.9(b)(6).) The court’s order provided the sanction would be set aside…