Sahafzadeh-Taeb

*128 Appellant Hamid Taeb and his attorney Michelle Trigger appeal from a *613 Code of Civil Procedure section 128.5 1 sanctions order, issued after Trigger failed to appear for trial in this dissolution case. We reverse as to Taeb and affirm as to Trigger.

We publish this opinion to make explicit that no vestige remains of the holdings in San Diegans for Open Government v. City of San Diego (2016) 247 Cal.App.4th 1306 , 203 Cal.Rptr.3d 34 ( San Diegans ) concerning the requirements of section 128.5. Among other things, San Diegans held that an objective standard applies when determining whether a party's or an attorney's conduct is sanctionable under section 128.5, as it does under section 128.7. ( Id. at pp. 1314-1317, 203 Cal.Rptr.3d 34 .) As we explain, section 128.5 has since been amended to specifically overrule San Diegans on this point.

The law concerning the kind of conduct sanctionable under sections 128.5 and 128.7 has, thus, largely returned to its pre- San Diegans state-with a more stringent standard requiring subjective bad faith applicable to section 128.5, and a lesser standard, requiring only objective bad faith, applicable to section 128.7. As we further…