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June 02, 2011
  Pointers for Dealing With FAMILY COURT JUDGES (Difficult and Otherwise) - What Every Lawyer and PRO PER Should Know!
Posted By Thurman W. Arnold, CFLS

Working with Family Court Judges

I recently attended this year's annual AFCC (Association of Family and Conciliation Courts) Conference in Orlando. Two Canadian jurists put on a workshop entitled "Dealing With Difficult Judges," and they kindly gave their permission to share their materials with you. Many thanks to the Honorable Carole Curtis and to the Honorable Roselyn Zisman - both family court judges within the Ontario Court of Justice system. I summarize their observations and suggestions here, and add a few of my own.

As these two bench officers point out, judges like the rest of us can be difficult and reactive at times, and it can be quite challenging for attorneys and pro se litigants to know how to prepare for, and best behave within, the sometimes edgy or emotional atmosphere of family courtrooms. This tension, if not understood or managed correctly, can have negative consequences in terms of outcomes and more. My intention is not to imply criticism of our bench officers. Being an effective judge day in and day out requires vast knowledge and a patience and equanimity that would challenge even a Mahatma Gandhi.

I hope to have a frank discussion about how lawyers and self-represented parties might consider presenting their cases - or in working with cranky judges - in ways that are dignified and productive. My hope is to improve the civility and professionalism of the family court experience for all affected, and to help unrepresented parties to have a fairer access to justice.

Here are some pointers for how not to aggravate your family court judge or commissioner and a few thoughts about what to do if that happens, despite your best efforts. The opinions expressed herein are not one size fits all. I also want to start a dialogue about how to make the job of family law judges easier for them, or - to put it another way - to discuss a bit about how we might help them to help us.


Suggestions for Interacting With Family Court Judges

  • Rule #1: Be Prepared

Judges have little patience with attorneys, and pro pro litigants, who aren't prepared when they enter the courtroom. Many litigants don't seem to know what they are asking the court to do, why they are asking for it, and what the best legal or factual grounds are for the orders requested. Courts everywhere, but particularly here in California with the passage of Family Code section 217 (which requires live testimony hearings upon request), are grossly overburdened. Judicial resources are not sufficient to meet demand in these budgetary times, and this places a pressure and premium on directness and efficiency. Economic limitations can also make judges a lot crankier than if they had reasonable and adequate time and resources to manage their caseload and calendars.

Depending on County size, wealth and population, California Family Law Judges typically have between 20 and 35 or more matters on their morning calendars. In the afternoons they are often holding evidentiary hearings for the more conflicted OSC/Law and Motion litigants, or have blocked off afternoons for trials. If they are to move through these calendars by the end of the morning, brevity and efficiency becomes exceedingly important. When do we expect that they will find the time to read what is contained in possibly more than 30 files before taking the bench to listen to oral presentations and cross-examination? For the more diligent judges the answer may be evenings and weekends. Which is often when hard working lawyers likewise find the extra time that they need to prepare for hearings and trial.

Therefore, one of the biggest mistakes that agitates judges is parties or lawyers who aren't prepared and can't present their cases with clarity. If, as a lawyer who is directly paid to identify and communicate the justness of your client's position, you don't appear to care overmuch about your client's case then why should our judges care? Lack of preparation, especially for lawyers, is a cardinal sin.

  • Rule #2: Be Prepared For This Particular Judge

In jurisdictions with direct calendar assignments, where a judge is assigned to a case for all purposes or for all purposes possibly until the case is reassigned for trial, learn about the particular bench officer(s) who presides over your case. The more you know the better. Information allows you to make useful assumptions about a particular judge's attitudes and policies.

As Judges Curtis and Zisman note, the best judicial officers are predictable and consistent in their rulings. "A judge's value to the public as a judge is in direct proportion to the ability of the lawyers who frequent the court to predict how the judge will deal with a particular issue." I find this to be so true in my personal experience. Lawyers who know how judges tend to rule on a given issue can with confidence set their client's expectations realistically. Armed with such knowledge, both sides are in a better position to have productive settlement discussions that avoid a "crapshoot" and the associated risks and expense. Moreover, they don't waste time potentially infuriating bench officers with weak arguments that judges may made known that they rarely accept.

Lawyers who are active practitioners in any given court usually have good insights into local judge's attitudes. They may also be aware of information about a judge that is not generally available to the public, like their expertise, practice focus, and reputation before they took the bench. Knowing that while a lawyer your judge participated in a case that generated a published appellate decision on a move-away case, for instance, could provide you a wealth of ideas on how to tailor your presentation. Likewise, knowing whether a judge has been reversed is useful for making sensitive presentations.

Pro per litigants should consider observing a judge going through her calendar over the course of one or more days. You will learn tons about their judicial attitude from watching them in open court, and indeed you may witness other parties get scolded or reprimanded for missteps and so avoid the same mistakes. A simple but classic example is the family court litigant who brings a small retinue of family members who are there to provide familial support, some of whom cannot sit still without gasping, shaking their heads violently, or sobbing.

  • Rule #3: Notify the Court If the Case Will Be Continued the Day Before

Sometimes one or both attorneys or parties intend to seek a continuance of a hearing, possibly because they want to discuss settlement but often because one or both are not ready to proceed or has late papers to submit.

Different judges have very different attitudes towards continuances, particularly where they have already invested the time reading the materials and then are faced with a continuance request. Lawyers who know that a case will not proceed are well advised to contact the courtroom clerk at least a day in advance to give a head's up - otherwise, they may wind up with a judge who justifiably feels "put out" and therefore cranky. Some allow self-represented parties to give advance notice of agreed upon continuances, but the other side will need to confirm it. Often messages must be left on the clerk's answering machine, and you may not know in advance whether they were received or acted upon.

Where both sides have attorneys and a particular judge is known to permit it, counsel should always let the court know one or even two days in advance that the hearing is not expected to proceed that day.

  • Rule #4: Look At the Local Court Rules, If Any, and the California Rules of Court

Some counties or individual courts have local rules; many do not. Most judges have their own rules and styles, often never to be found in written form. It never hurts to ask the Court clerk, when the judge is off the bench, whether that courtroom follows any specific preferences, customs, or rules of procedures. 

The state-wide source for procedural rules impacting California Family Law (and Juvenile cases) are the California Rules of Court, beginning with Rule 5.100. Rule 5.118 is one of the immediately most important, since it deals with initiating common OSC and Motion requests for custody, support, etc. These rules apply to all family law matters in all California courtrooms.

The Riverside County Local Rules pertaining to Family Law cases can be found here. Start with Title 5. I discuss these in more detail below. The Los Angeles Family Court Rules can be accessed here. Basically you ought to go to the County website where your case is filed and look for the local rules for that particular venue. If they exist you will be well served to review them for relevant tips and local policies. 

  • Rule #5: Talk to the Judge, Not the Other Party or Lawyer

The time to discuss your case or argue with the other side is before you enter the courtroom. It drives judges nuts when two lawyers, two pro se parties, or any combination of them begin to argue at counsel table as though the judge was not present. Keep your focus on the judge, and generally avoid looking at the other party except for emphasis. Never address them directly.

A very important related concept is that if you bring witnesses or support people in the courtroom, tell them in advance to keep control of themselves. This means no interruptions, no head shaking or head nodding, no gasps, and no agitated movements. It is natural that the people your bring to the hearing have a some degree of investment in the outcome. However, when these people act in an uncontrolled fashion, that may affect the court's evaluation of you. Thorough lawyers always remind clients and the support people who accompany them to maintain a even demeanor and not to speak unless spoken to.

  • Rule #6: Never Assume the Court Has Read the File, and Never Ask

Judges can be easily overwhelmed at times for any number of practical or personal reasons. Never assume the Court has read your pleadings, but at the same time it is pointless to ask him if he has. Asking the question not only embarrasses the court, if they answer that they have not read it and you wind up getting what you wanted, you are inviting an appeal since appellate courts in California have reversed trial courts for ruling on matters where they've admitted on the record they've not read the file.

Instead, start your presentation as though the Judge has not read the materials. Most judges will interrupt you to advise you when they have read it. Be nimble. At the same time, understand that the court only has enough time to listen to summaries of information, not the entire case. You need to know in advance what your highlights are soundbites are, and they should be presented in as orderly a way as possible. Having outlined these in advance is very helpful in the heat of the moment, where you become distracted by some exchange you did not expect and must return your focus to your goals. Outline your highlights on a notepad in a way that a given sentence triggers your memory of the remaining points you wish to make.

  • Rule #7: Make It Easy for the Judge

This is one of the greatest challenges, particularly for young lawyers and self-represented parties. How to know what matters and what does not? You want to help the judge to help you, and in doing this you need some ability to discern what is legally or factually important to them.

The first and best opportunity is to do this in the papers that are filed when your OSC or Motion is drafted, or when replying to the other side. Here it is extremely important to know the local court rules, if any, as they pertain to how paperwork is prepared plus - use common sense.

These papers give the court the first and sometimes defining impression of the case. They are probably your biggest opportunity for persuasion. Their purpose is to instruct the Court, and to explain the justness and reasonableness of your position. Backbiting and attacking the other side, or their attorney, and engaging in irrelevant and personal argument, is not going to be helpful. Like many of the suggestions I make in this Blog, this is often hard when locked in divorce trance, whether as a trained advocate or not. In declarations consider inserting spreadsheets, Excel boxes, and tables where a point can be made visually and simply.

Most judges are older people, and their eyes are not those of a 30-something adult. Double space your writings; use at least 12 point font; some judges insist that Courier or Times Roman be used; others insist that you use recyclable paper. Never handwrite your papers where you can avoid it, except possibly in cases involving domestic violence restraining orders requests (since the Judicial Council forms are handwriting friendly); nonetheless, typewritten language should always be preferred. Do number sequentially the paragraphs in your declarations. Organize your work for ease of access.

Avoid using CAPS or Bolding, except possibly for titles and organizing sections of your written submissions, since many of us today interpret that as shouting.

The likelihood that the court will fully read your pleadings increases proportionately with its brevity and readability. Most judges consider more than eight pages to be way too long. Reduce and edit your work, and then reduce an edit it some more. I am reminded of a literature class I took in college that studied the works of Ernest Hemingway. As I recall it, he would edit and review all his work to use active verbs and cut, cut, cut unnecessary verbiage. Similarly, when the other side submits a lengthy pleading resist to impulse to respond in kind. Be surgical. This can be a tall order in family law cases, since there is so much emotionality and reactivity in "he-said", "she-said" exchanges. But try. Respect how little time a court has to review one of twenty files set for any given calendar.

Do not include evidentiary submissions in pleadings, and consider tabbing or page numbering your exhibits and then referencing those page numbers or tabs in your declarations (by page, paragraph number, or line number). Remember, if the judge can't find what you are referencing, they will not like read it. This is a tough call in my experience, because it is good practice to provide evidentiary support for claims you make and positions you take. But too many attorneys and most all pro pers I've encountered submit way too much paperwork, and I confess I've done it too.

Some courts will allow counsel or the parties to contact the clerk in advance of hearings to warn that the issues are more complex than normal. This may be a wise step on your part.

 

  • Rule #8: Avoid Head-Butting With the Judge (and the Other Side)

Whether or not a judge seems difficult or cranky, it does not help to get into a head-butting contest with him or her because you just can't win it. Head-butting may be a "kiss of death" for an advocate; the issues themselves have degenerated into an ego contest, and if you are in court to serve your ego you will likely have an unpleasant outcome. Remember, people are watching, including court staff. The Judge not only knows that she is the supreme power in the courtroom, she has her dignity to protect. Confrontations with judges suggests a battle between equals, and you are not equal. It also implies a winner and a loser. If you head-butt with a Judge, you are asking them to prove to everyone present who is in control. That usually ensures that you will be shown to be the loser for the simple reason that finding in your favor may then imply that you are in control.

Head-butting might well begin with an attitude on the part of the judge. If this occurs, move into "damage control." Immediately lower your tone. Avoid flailing hands or arms. Speak evenly, slowly, and respectfully. This may defuse the situation before it becomes impossible to redeem. As Judges Curtis and Zisman put it "You must do whatever you can to end this contest. Consider a retreat, whatever that means in the circumstances. Move your reaction into this range...:  be calm, be measured, be focused, and be polite (be unfailingly polite)." With a particularly difficult judge, the hotter it gets the calmer you must become.

A cautionary note here: Many judges I know respect an advocate or a person who will stand up to them, and not simply fold because there may be some debate. So much depends upon your tone and style even as you perhaps stubbornly, but calmly, present your arguments or evidence. Hence, do not take these suggestions as meaning that if the judge seems to disagree with you that you should become silent. It is how you convey your message that often matters most.

Be persistent, unless it becomes obvious that the Court has heard enough. Often judges will tell you this.This can become a real problem if you have not had the opportunity to make "a record" for purposes of a possible appeal (something you never want, but sometimes must consider).  If you are foreclosed from making a record, you should note that respectfully before quitting.

Similarly, it is usually pointless to argue with a judge once they have ruled on any given matter, but if you feel there is more to say and you are uncertain whether the judge has heard as much as she will, you might try "Your Honor, before the court moves on, might I add one more thing?" 

  • Rule #9: Never Lie to the Court

It is amazing to me how often attorneys will intentionally misstate facts to the court, or create inflammatory arguments that has little basis in fact. I am sad to tell you this happens a lot, and in fact this is one reason why divorce attorneys may be viewed as bottom feeders. Yet, this is only a small, if vocal, segment of the legal practitioner population. Similarly, parties in relationship disputes are highly motivated to misrepresent information for more directly obvious reasons. 

As a advocate, one of the most important things that lawyers possess is their reputations. Judges who will talk about it will candidly admit that they are every bit a catty lot as the next person or profession. The talk in chambers, they talk in lunchrooms, they talk in restaurants, they talk in meetings amongst themselves. One of the common topics is about the lawyers who come into their courtrooms. Their views about particular attorneys' reputations can be infectious within the judicial community, which is not to suggest that they do not attempt to remain impartial on a case by case basis. It is true that sometimes it feels that attorneys who too freely spin the facts get away with it. This is one reason I am a proponent of monetary sanctions against attorneys directly, something I suggest in my Davenport Blog. One consequence of unaccountability is that opposing sides, and unrepresented parties, take their cues from the lawyers they come into contact with and mimic bad behavior of those they observe. The behavior of legal professionals matters. terrible message to send. There are so many reasons why it is imperative that lawyers not be deceitful.

Never lie to the Court, whether you are a lawyer or a party. Once a judge gets fixed on the idea that your information is untrustworthy it will pervade his view of you within your case, and is likely to haunt you. There are subtle and not so subtle ways of punishing litigants by imposing outcomes that can be catastrophic for your life, from fixing alimony or support orders above your level to pay to depriving you of time with your children. And, be advised, lawyers love it when the other party lies. This is exactly what can be seized upon to win their client's case, sometimes far more dramatically than when people just admit the weaknesses in their positions and move on.

  • Rule #10: Don't Tell the Judge it is Obvious She's Already Made Up Her Mind

It does happen that lawyers and parties may find that the Court has prejudged the case before any oral presentation; an example being the circumstances identified above where the lawyer or litigant has lost all credibility. But at other times it can be very difficult to understand why a bench officer may seem to have already decided your case before you open your mouth.  

This is a tough one there may not be much that you can do about it. The advice of judges Curtis and Zisman is to stay calm and focused, and just keep going. Don't respond with something like well, "I can see your honor has already made up your mind," and don't otherwise communicate this with your body language, glares, or tone. This too can be a tall order. But on balance neither the client nor their case can be served in this fashion. For lawyers, my experience is that clients better appreciate the fact that you remained professional rather than snotty with the judge, because they will watch in real panic as their spokesperson begins to lose his or her poise. Similarly, they will know you did everything you could where you don't pour accelerant on the fire.

Judges Curtis and Zisman suggest that lawyers and parties need to know, under such circumstances, when to fold. They also need to know how to protect the record - that is what is said on the record that is recorded by the court reporter. As with the rude and abrasive judge discussed below, a good record for an appeal may be your only hope especially in jurisdictions that video or audio record the hearing, since tones of voice and sarcasm are often lost in a written hearing transcript. And, beware, I once had this happen with an extremely difficult Juvenile Court Judge (retired some years now) and so made a request for the written transcript (which was all that was available), and when I received it I found that major portions had been edited out entirely. Obviously the judge had instructed the court reporter to falsify the transcript, but how was I to prove it? I did manage to get a Writ of Mandate on appeal that removed the judge from future hearings in the case, and then won it in front of a much better judge at trial. BTW, proof that a judge has doctored the hearing transcript would almost certainly result in judicial discipline if proved, but that is can of worms I do not recommend since if your attack on the court fails that judge might actually make it their mission to ruin an attorney or their case.

  • Rule #11: Don't Duke it Out With the Rude and Abrasive Judge

Unfortunately I witness this more than I care to admit as an observer at courthouses, although very rarely in my cases these days and one possible reason is that I usually know when to shut up. Judges Curtis and Zisman state "Some judges are rude, aggressive, even abusive, for no apparent reason, or at least none that justifies this behaviour. It is extremely important for the lawyer (or the party) to be calm, and to remain calm, polite, [and] focused." I quote them directly to reinforce that I am not one lawyer griping about judges; similarly, I have friends who are retired bench officers and they will admit that such conduct occurs, and even that at times they regrettably engaged in it. 

The goal of lawyers in such situations is, above all, to defuse the situation. This may seem an impossible task, particularly when it is our job to protect our clients. If the behavior is really so over the top that our clients are being abused we must object to such behavior.

All I can recommend to nonlawyers is that they not get sucked into such exchanges with the court, but that at the same time they politely and firmly stand their ground.

  • Rule #12: Ideas for Coping With Judges Who Do Not Know Family Law

California matrimonial law is immensely complicated. Many lawyers who regularly practice in family court really have little clue what they are doing, in part because the simpler contests arise over and over again and many lawyers learn enough to deal with these simple situations but would be highly stressed on more complicated situations. Likewise, many family court lawyers have very little actual trial or even deposition experience. They don't know how to cross-examine witnesses. They only have a glancing familiarity with rules of evidence. Some of these lawyers actually go on to become judges. Others may be quite skilled in the criminal arena, for instance, where they were once prosecutors or public defenders. These judges were once real trial lawyers, but that doesn't mean they understand family law. Others may have been quite senior civil litigators who nonetheless rarely if ever handled these types of cases. 

Curtis and Zisman point out that this situation is actually more easily remedied than some of the others discussed here. They suggest that particularly when you know that a bench officer is not overly familiar with this area, that you adjust your presentation to ensure that you covering the basics. State what you are asking for, identify any statutory authority, and discuss the legal standards that apply. One of the reasons I blog so much is to popularize information to empower nonlawyers. Lawyers have lots of legal treatises to subscribe to and review (when they bother); the public generally does not have these so nearly accessible. I hope this website aids you. However, please remember, my blogs and articles are intended merely to be educational and it is impossible for me to guarantee their accuracy under any fact pattern. You have to do your own work and draw your own conclusions.

  • Rule #13: What to Do With the Judge Who Hates Family Law

This is usually a function of judges who don't know family law although as you might suspect, a jurist who hates family law is likely not going to bother to learn it. The best way to overcome this problem is to be polite, be brief, and educate the court about what you want and why you are entitled to it. If you have no idea as to either, the judge who hates family law may become an abusive judge as well. Politely and firmly resist being rushed. But get your points in clearly.

  • Rule #14: Cite Recent Authority Whenever Possible

If you are identifying statutes or law that you believe impacts how the judge should rule on your case, try to identify recent materials and consider having a copy of them with you. For instance, I often Blog appellate decisions that may only have been published for the first time a few days before. These cases haven't hit the law books yet. The judge may likely know nothing about them. Be sure to bring copies of the case to the courtroom to give the bailiff to hand the judge, and be sure to provide one to the other side (hopefully before the hearing begins). 

Because family law changes so rapidly, some judges only want recent authorities.

As to statutes, most that have been amended in any given year change effective on January 1 of the following year. If you are at the cusp of year's end, consider double-checking relevant statutes in advance of your hearing or when you prepare any written Points and Authorities. The Web is a great resource for these materials, as is my website, since I will attempt to give the public a heads up on important changes beginning November and December each year.

  • Rule #15: Never Try to Submit Late Declarations

I often see pro pers bring in late declarations and try to file them just before a hearing, often refusing to first give them to their opponent or their lawyer. I can't recall how many times I have had a self-represented party tell me that they intend to submit something to the Court but they wont let me have a copy until the Judge says so. 

Judges almost universally will not consider late papers, and I promise you that the first words out of my mouth in such situations to the court will be that Mr. So and So has some additional declarations to file, but refuses to let me see them. Even lawyers play this game. Don't do it. It is the kind of conduct that may bias the court against you, and the risk reward ratio doesn't merit such behavior. Why blow yourself up at the outset?

If this happens to you on the receiving end object politely, at once. Know the rules of court provisions I've given you and any others that may apply and point out that the time to file papers expired. If a judge indicates a willingness to consider these matters, ask for a continued hearing so that you may review and respond to them. If the hearing proceeds respectively ask the Court to strike any oral version of the materials that didn't get filed.

  • Rule #16: Understand the Rules Relating to Proofs of Service

I cannot tell you how often court submittals are rejected by the clerks, or hearings don't go forward, because there has not been an adequate proof of service filed with the Court. Even when late papers are accepted by the clerk,, judges often refuse to read them. Late papers burden jurists, and they aren't proper. Procedural due process within the adversary legal system requires that both sides have full and fair notice of what relief is being sought, and what is being alleged. There are strict time limits for perfecting Proof of Service, which are complex enough to tangle lawyers up as well. 

If you haven't perfected service, the best case for you is that you've wasted your day and your matter will be continued; the worse is that your materials will not be considered, or even that your matter will not be heard at all. A good idea is to consider asking the others side in advance for a continuance and get them the papers by fax or personal delivery at early on as you can, and tell the judge you did so when they insist on going forward and objecting to what you wanted to present.

  • Rule #17: The Judge Who Won't Let You Argue the Case

This is common, particularly given that law and motion (and OSC) calendars are short cause hearing settings. This is something you definitely should ask the court clerk about in advance. However, it tends to be moving target depending upon a judge's frustration level on any particular day. Judges regularly will ask litigants, particularly pro pers, to look behind them at all the other people waiting to be heard "by me" today. You may be told that you be coming back after lunch if you cannot conclude your matter within a specific time frame.  

Trials are a different matter. For non-trial order to show cause hearings assume that 10 minutes may be all you get.

As with all difficulties encountered with judges, try not to draw attention to the fact that the court is shutting you down or otherwise criticize the court, unless there is no option but to do so in order to protect the record. Which almost certainly means you've lost this round.

  • Rule #18: What to Do With The Judge Who Can't Stay Out of the Arena

Unlike many other legal areas, courts have some independent duties to investigate the facts of a case beyond questions that lawyers or parties might think to ask or decide not to ask because they know they won't like the answer. An obvious example is the best interests test in child custody and visitation proceedings.  

Those of you that remember Paul Newman in The Verdict may recall what this circumstance can look like. There is not much to be done, except not to go off and to remain calm.

  • Rule #19: Know When to Fold

This is a painful reality for both lawyers and pro per litigants. Sometimes retreat is the only option. It is a corollary of much of what has been discussed above. If you aren't getting anywhere, end the line of questioning or the argument. Young lawyers particularly don't know when to go silent. Pro pers seem to have a better sense of it, because they tend not to be as susceptible to ego battles with a judge as a lawyer filled with righteous indignation.

  • Rule #20: Be Reasonable

I find this one of the most important and effective of tools to obtain good and fair results in the courtroom, even when I can't achieve every single one of my client's goals. Reasonableness speaks to credibility. It also assumes that possibility of some win-win, and enables the Court to feel it has achieved substantial justice. Judges don't generally like giving one side everything they ask for, unless of course they are really pissed at the other side.

  • Rule #21: Treat Everyone With Respect

Clerks and deputies are watching everything that happens in and outside of the courtroom, and are part of the Judge's family. Treat them with respect and realize that they are sizing you up as well, and possibly even directly or indirectly reporting to the judge. Treat them gently and with respect. Don't think you can behave like a jerk in the hallways without it possibly being seen and reported. 

A particular problem area can arise here in dealing with Court minutes, which are taken by the court clerk. It is not uncommon for these minutes, which absent a transcript being ordered become the only written record of what transpired, to be incomplete or even incorrect. This happens, unfortunately, often but is easily understood things often move rapidly and emotionally during hearings. If it does happen and a formal order is submitted it will usually be rejected as not conforming to the Court's minutes. Ideally recite the court's orders back to the court for the benefit of the court clerk, and do it slowly and even look at them gently when you do it.

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April 30, 2011
  271 SANCTIONS Ordered Against PRO PER ATTORNEY - Lawyers Are Some of the Most Conflicted Parties to Matrimonial Litigation
Posted By Thurman Arnold, C.F.L.S.

I have recently been reflecting on the fact that in my experience, lawyers who are parties to family law litigation behave far worse than most people suffering through the emotional ravages of relationship breakup. There is something about being a lawyer that threatens, and for some tends, to transform us into bullies and petty tyrants.

Lawyers should be even more mindful than the average litigant about taking bad faith positions. Courts hold attorneys to a higher standard, as they should. Not only are they more likely to be monetarily sanctioned for abusive behaviors, attorneys may also find themselves the focus of a State Bar investigation that ends with discipline including suspension or disbarment - an accountability unique to being a member of the legal profession. Hence, attorney pro se litigants have a lot more to lose than the average disputant. Aside from their ethical obligation to be act better than the rest as "officers of the court," there are practical reasons why they should exercise restraint.

There is a trend among our California appellate courts to fix boundaries and impose consequences for all divorce litigants who engage in uncooperative and dishonest behavior in marital and partnership dissolutions. This is a good thing: As I urge in my Blogs, the family law system for resolving disputes isn't working because the participants often approach them with so much blind rage and reactivity that their conduct overburdens the courts' resources and are too often manifested in attempts to beat the other person into the ground by increasing costs unnecessarily, by misrepresenting information, and by playing "hide the ball." We teach our children to self-regulate their behaviors, but sometimes we can't seem to get a grip on our own. We don't want judges to act as through they were our parents, but people often force them to.


Marriage of Greenberg (April 28, 2011) 194 Cal.App.4th 1095

As if to emphasize this phenomena, the Second Appellate District out of Santa Barbara issued its decision in Marriage of Greenberg on April 28, 2011. Self-represented Attorney Robert Greenberg was sanctioned in the amount of $2,800 in attorney fees to be paid to his former spouse by a Ventura County trial court when he took a meritless position to justify his stubborn refusal to pay a court ordered equalization payment to her. The trial court found that he was not only not credible in identifying his income in opposing a spousal support request, but declared that he'd engaged in perjury about his earnings and expenses. Moreover, the argument he urged to avoid paying the equalization payment was one that "should not have been an issue in the first place."

Accordingly, per Family Code section 271 sanctions were upheld as entirely appropriate and within the trial court's discretion. But that is not what is striking about the court's decision - and indeed $2,800 for uncooperative and dishonest behavior in family litigation is a very light slap.

Mr. Greenberg was not satisfied to accept his lumps and move on; instead, he filed a frivolous appeal from that order. Because Wife had not filed any brief in opposition to Husband's appeal Husband dodged a second monetary sanctions' award - but he did not dodge the bullet. BTW, Husband may have believed that because Wife could not afford to hire an appellate lawyer, given that it makes little sense to pay $10,000 to defend a $2,800 judgment, he would win in effect by default - he was sorely mistaken, however, since appellate courts don't accept arguments as valid simply because they are unopposed.

The Court concludes its opinion with the following:

"The record on appeal does not show that the trial court reported husband to the State Bar. We order the clerk of this court to send a copy of this opinion affirming the trial court's order to the State Bar. Whether husband should be disciplined is addressed to the judgment of the State Bar and we express no opinion thereon."

I suspect the author of that final sentence was smiling when they wrote it. Given the citations to Mr. Greenberg's tactics in the appellate record, it is hard to imagine that he will not be sanctioned by the Bar in the near future. Ironically, if the trial court's perjury findings have not previously been brought to the attention of the State Bar, Mr. Greenberg's insistence on pursuing a frivolous appeal guarantees they now will be. This is a wonderful example of an obsessed divorce litigant completely 'blowing themselves up.'

Justice Yegan, J. for the Second Appellate District begins this strongly worded opinion with the sentences: "Abraham Lincoln once said, 'He who represents himself has a fool for a client.' Here, the client is an attorney who represented himself in the trial court. He now represents himself on appeal. He is unschooled in the basics of appellate law, suggesting that Lincoln's observation applies on appeal. We understand that emotions run high in family law litigation and that this may cloud the  judgment of a party. But that does not excuse the filing of a 'creative' (i.e., misleading or incomplete or inaccurate) income and expense declaration; or perjury,..., or the filing of a frivolous appeal." [Italics added].

The decision ends with this dry and understated observation: "Husband, a pro per attorney, suffers from a lack of objectivity." This fact, universal in differing degrees for those who are ending relationships, is at the core of why family litigation is so distressing and expensive for everyone involved, and in need of a major retrofit. But in the meantime, trial courts are repeatedly being given the green light to reign in parties who act like errant children so long as their due process rights are duly protected. Along with Marriage of Tharp, Marriage of Fong, and Marriage of Duris & Urbany, Marriage of Greenberg constitutes a warning to all family law litigants that abusive conduct will not be countenanced.

Also, Greenberg is important as good authority for the proposition that unfounded legal positions at the trial court level are sanctionable under FC §271. It should be cited to any judge where you encounter difficulties with the other side that sound familiar here, including advocating meritless claims.

Divorce trance is strong stuff. It causes most people to lose their minds for a time, before they can regain some balance and equanimity. Some high conflict litigants seem to never regain their poise (if they ever had it), and lawyers as parties to matrimonial matters seem to personify some of the coarsest aspects of our lower natures. One of the benefits of hiring a seasoned attorney, even if you think you can otherwise represent yourself, is that they can guide you to act in ways that are less destructive than what your impulses demand. Good lawyers don't just perform the mechanics of divorce, they help to set the tone. Conversely, seeking out "aggressive" lawyers whose advice mirrors or panders to your inner tension assures that your experience of the divorce and of the courts will be all the more unpleasant and unsatisfactory - oh, and expensive too.

Do yourself a favor - don't imagine that family court is your stage for expressing your upset and rage. Throw tantrums and the consequences may be more painful than a "time-out."
 
Or consider a different tact, if you wish and if your limbic "lizard" brain will allow it. Fortunately, we have other areas that we can access with just a smidgeon of mindfulness.

Thurman W. Arnold, III, CFLS

A disclaimer: 

Very few humans can behave impeccably every time, and I don't want to create an impression that I claim to be freed from all personal reactivity. My discussion is aimed at reminding you and I that we have two primary choices: 1) Get lost in the trance of resentment and within our busy minds, and so be persistently and stubbornly deprived of any real decision-making ability or 2) to increasingly gently and firmly restore and ground ourselves, and exercise the choice to suffer less rather than more by resisting the impulse to jump and scream when we feel threatened or angry. This latter possibility exists apart from all proclaimed external "causes" to our misery - and requires that we not respond in kind to the perceived insults and injustices that others may seek to inflict upon us.

Every day we enjoy a fresh chance to re-evaluate our direction and so to reset our conditioned negative momentums. Might succeeding one time in ten be better than the alternative?

When I am distressed but lucky, the mantra "stop..., clear..., reset" sometimes comes to my mind. And sometimes, hopefully more often than not, this works for me. Find your own mantra and save yourself from needless pain.

The opportunity for freedom resides within us, not without! Conversely stated, victims tend to choose to be.
Continue reading "271 SANCTIONS Ordered Against PRO PER ATTORNEY - Lawyers Are Some of the Most Conflicted Parties to Matrimonial Litigation" »

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March 07, 2011
  Making DIVORCE JUDGES ACCOUNTABLE - What Is A STATEMENT OF DECISION?
Posted By Thurman Arnold, CFLS

Given the 2011 changes to the California Family Code brought about by the recommendations of the Elkins Task Force, you need to know about something called a "statement of decision". This is because many family law cases involving temporary or interim orders now require an evidentiary hearing - or a trial or 'mini-trial' - on matters that used to be decided as motions based only upon declarations and argument of the parties or counsel. California Code of Civil Procedure §632 governs this device, and it is not available in straight law and motion proceedings. It is available only on matters where there has been a trial of factual issues.

Newly enacted Family Code §217 directs family court judges and commissioners to hold hearings with live testimony unless the parties stipulate otherwise, or unless the trial court finds good cause to dispense with such hearings. I've written about the Elkins changes extensively elsewhere on this Blog, so please try the search engine at the top of each page for more information about them.

A statement of decision requires the family law trial court to state, on the record, or in a subsequent written opinion, why it ruled the way it did on any questioned fact. It is essentially the same thing as a statement of the court's findings and its conclusions on any controverted issue. Judge's don't necessarily appreciate such requests, however, because they force the bench officer to expend additional time to explain at least some of the aspects of their reasoning, and some feel that it is provocative to ask them to explain their reasoning; the conventional wisdom for lawyers therefore is "don't ask unless you fear you are going to lose." 

Statements of decision in family law cases, as with hearings on OSC requests and certainly bifurcated or full on trials, are most important as a tool for a potential appeal. Without them the record on appeal may be quite unclear since the appellate court will have a difficult time determining the fact basis for the trial court's reasoning. Effectively, absent a SOD, this means that the appellate court will only reverse the trial court ruling for errors at law - the reviewing court will presume that the trial court made every factual finding necessary to support its decision. This is one of the problems of asking for them - you are saying to the judge "I think you may rule against me and so I am doing this to protect the record on appeal."

There are important rules about when to request a statement of decision. Where a trial is completed in one calendar day or less (or less than eight total hours over several days), a request for a statement of decision must be made before the court issues its ruling (i.e., before the matter is submitted for decision). This means, before you hear the judge's ruling, not after! There are technical rules about how to add up these hours. This will be the typical family law OSC or Notice of Motion situation where testimony may last from 30 minutes to several hours under FC section 217. Until January 1, 2011, these situations typically included only domestic violence hearings since evidentiary hearings were already required in those cases.

The procedures for statements of decision are to be contrasted with certain statutory requirements that courts make and express their findings on the record in certain statutorily enumerated situations, whether or not these are specifically requested. I will identify those sections in the future.

Check back for further Blogs and pointers on these subjects. If you have a contested hearing with testimony, and you get the sense the judge views things differently then you do, ask for a statement of decision before you hear the decision!



Thurman W. Arnold, III
Certified Family Law Specialist

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September 18, 2009
  Idaho Trial Court Rules that Mother Cannot Move to Michigan, Even Without the Kids!
Posted By Thurman Arnold

I just have to blog this news from Idaho to reinforce why clients are so often better off resolving their disputes then asking judges - who mean well - to decide for them.

In Allbright v. Allbright the parties divorced and entered into a stipulation requiring 60 days notice before either moved out of Bannock County, Idaho, if it rendered the parenting plan impractical. Mother remarried, and 2 years later her new husband lost his employment. He was only able to find employment in Michigan. Mother gave notice of her intent to move to Michigan. At that time she had custody of the parties' minor daughter 54% of the time. Father responded with a motion to give him custody. The parties sought recommendations from a psychologist, who conducted a custody evaluation and recommended daughter be allowed to move to Michigan with mother. He recommended a custody manager because of the "considerable hostility" between the parents. Father wasn't happy and convinced the trial court to appoint a second custody evaluator, who recommended that Father retain custody if Mother moved. 

The case was tried in the summer of 2008. At its conclusion, the court asked the parties' attorneys to brief whether it had the power to order Mother not to move at all, whether with or without the daughter.

Father urged that that child's best interests were (and would always be) best served if the parents remained in the same vicinity so that joint parenting could be shared. His lawyer argued that the child's best interests trumped every other consideration or right, such that a trial court could even, for example, order divorced and warring parents to live next door to each other or in the same house if it determined that was in the child's best interests!

The trial court evidently agreed, and ordered that Mom must not move out of Idaho whether with or without the daughter. Mother was hence enjoined to become a prisoner within that state, while her new husband continued his life in Michigan.

Thankfully, the Idaho Supreme Court disagreed with the trial court, but only after Mom probably spent thousands in legal fees defending her right to move. The high Court ruled: "A court presiding over a child custody matter does not become a family czar with unlimited authority to order the parents to do anything that the court believes is in the best interests of the child."

Yet, upon Mother's request to be reimbursed for her legal expenses, the Idaho Supreme Court was unsympathetic declaring that "[b]ecause we have never before addressed the issue of whether a court has the authority to prevent a parent from relocating, we do not find that Father defended this appeal frivolously, unreasonably, or without foundation." 

My comment:  It is always a dangerous matter to fail to resolve matters collaboratively.
Here is a link to the Idaho Supreme Court's decision in  Allbright v. Allbright.


TWA
Continue reading "Idaho Trial Court Rules that Mother Cannot Move to Michigan, Even Without the Kids!" »

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