Sanders

INTRODUCTION

It is not an abuse of discretion for a trial court to issue sanctions against attorneys who intentionally violate court orders. That is what happened here. This appeal stems from a custody dispute in divorce proceedings between a mother and father. The parties ultimately resolved the custody issues by agreement, except for one dispute over how their child’s summer vacation would be allocated. The trial court issued a tentative ruling awarding father most of the child’s summer vacation. Afterward, mother’s counsel requested—and was granted—permission to draft a proposed statement of decision memorializing the court’s tentative ruling. However, rather than draft the proposed statement, mother’s counsel instead submitted a document attacking the trial court’s credibility and tentative ruling. When the trial court took issue with counsel’s submission, mother’s counsel volunteered to prepare and submit a revised proposed statement of decision. This second proposed statement similarly failed to capture the reasoning or basis for the trial court’s tentative ruling, and again impugned the court’s credibility in awarding summer vacations to father. In response, the court…