California, United States of America
The following excerpt is from Post Apple LLC v. Acrew Mgmt. LLC, A142859, A143832 (Cal. App. 2015):
has succeeded in clearing title, which in this case was accomplished in principle at the time of the settlement agreement entered into on June 18, 2013, the ability to recover attorney fees is cut off. Prior to that date, it is impracticable, if not impossible, to separate the attorney's time into compensable and noncompensable units given how interrelated the causes of action for slander of title, quiet title, ouster, ejectment, and partition are and how they all center upon the documents that clouded title. Bell v. Vista Unified School Dist. (2000) 82 Cal.App.4th 672, 687.
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