Murray

— Following a jury trial, respondent Linda Murray obtained judgment against her adoptive father, Robert Athanasius Murray and his wife, Carol Ann Slater Murray. The judgment quieted Linda’s title to a certain parcel of real property, awarded her damages of $60 each against Robert and Carol, and awarded her an additional $70,000 against Carol alone for attorney fees incurred in the action. Robert and Carol appeal, raising a multitude of issues. We will conclude that the award for attorney fees is not legally sustainable but that in all other respects the judgment was proper. We will modify the judgment accordingly.

Factual and Procedural Background

Linda’s mother, Dianto Chomette, married Robert Murray in 1969 and in 1972 or 1973, Robert adopted Dianto’s four daughters, including Linda.

In 1974, the family was in the process of constructing a house on a lot in the Squaw Valley area of Fresno County at 37049 Totem Lane. The lot had been purchased by Robert and Dianto and construction undertaken with money loaned them by Dianto’s mother, Germaine Chomette. Title was placed in Germaine’s name, as Robert “wanted [his] name nowhere on it.”

In June of 1974, a deed was…