Does a plaintiff have to provide a statement of decision to support his claim for attorney fees?

California, United States of America


The following excerpt is from Alcone v. SLV Assocs., LLC, G051813 (Cal. App. 2016):

The plaintiff in Ketchum v. Moses (2001) 24 Cal.4th 1122 made a similar argument, i.e., "that the superior court erred by failing to provide a 'reasoned explanation' for denying his objections to specific items in the billing records." (Id. at p. 1140.) Rejecting this claim, the court stated: "The superior court was not required to issue a statement of decision with regard to the fee award. [Citation.] Moreover, although [defendants] opposed the motion for attorney fees, [they] did not request a statement of decision with specific findings. '"All intendments and presumptions are indulged to support [the judgment] on matters as to which the record is silent, and error must be affirmatively shown."'" (Ibid.)

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