Can a defendant in a personal injury action obtain attorney fees?

Reading contends that attorney fees could not be awarded given that the court ruled it did not have jurisdiction. Shisler v. Sanfer Sports Cars, Inc. (2008) 167 Cal.App.4th 1, 9, held expressly to the contrary, concluding: "Since the trial court had jurisdiction of the subject matter and jurisdiction over plaintiffs, there was no jurisdictional impediment to defendant's specially appearing to call upon the trial court to enforce its statutory right to fees." Reading claims Shisler "was incorrectly decided" and doesn't cite any California law.