Webb v. Webb

*877In this appeal, we are tasked with interpreting Family Code section 271 which authorizes the trial court to award attorney's fees as a sanction.1 The precise question for us is whether the statute permits an award *878of sanctions to non-parties to the litigation. The trial court concluded that it did, awarding approximately $88,000 to a party's former counsel. We decide that section 271 does not authorize the court to award sanctions to non-parties, but rather is intended to promote settlement of family law litigation through shifting fees between the parties to the litigation. For this reason,…