What is the standard of review for attorney fees awarded after trial?

California, United States of America

The following excerpt is from Sui v. Price, G052248 (Cal. App. 2016):

"'On review of an award of attorney fees after trial, the normal standard of review is abuse of discretion.'" (Connerly v. State Pers. Bd. (2006) 37 Cal.4th 1169, 1175.) De novo review is warranted when an appellate court must construe a statute to determine whether the criteria for an attorney fee award has been satisfied. (Id. at p. 1175.) The party challenging the award bears the burden of affirmatively demonstrating error. (Ketchum v. Moses (2001) 24 Cal.4th 1122, 1140-1141).

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