Webb

*877 In 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 *878 of 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, we reverse.

FACTUAL AND PROCEDURAL BACKGROUND

1. The 2009 Petition

William Webb and Deborah Webb were married in 1997. On March 4, 2009, William filed for divorce. Deborah was represented by Sandra Polin and the Law Offices of Sandra Segal Polin in the proceedings. The parties agreed to dismiss the action on April 22, 2010.

2. The 2012 Petition

On February 29, 2012, William filed for divorce again. In March 2012, Deborah retained Patrick DeCarolis and his firm Trope & DeCarolis, as well as Polin, to represent her in this second action.

3. William Opposes DeCarolis's Notice…