California, United States of America
The following excerpt is from Hines v. Premier Power Renewable Energy, Inc., G049912 (Cal. App. 2014):
In addition, Premier argues the attorney fees should have been apportioned because under section 218.5 the prevailing party may only recover fees on statutory causes of action. It cites authority holding, "'When a cause of action for which attorney fees are provided by statute is joined with other causes of action for which attorney fees are not permitted, the prevailing party may recover only on the statutory cause of action.'" (Bell v. Vista Unified School Dist. (2000) 82 Cal.App.4th 672, 686-687.)
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