A court may base an attorney fees and costs award based “on the extent to which the conduct of each party or attorney furthers or frustrates the policy of the law to provide settlement of litigation and, where possible, to reduce the cost of litigation by encouraging cooperation between the parties and attorneys.” Fam C §271(a).

A trial court must be able to apply sanctions during course of litigation when uncooperative conduct arises, to encourage better behavior as litigation progresses. Marriage of Feldman (2007) 153 CA4th 1470, 1495.

Because of the nature of sanctions, the requesting party is not required to demonstrate any financial need for the award. Fam C §271(a); Marriage of Falcone & Fyke (2012) 203 CA4th 964, 990.