What is the standard of review under the California Records Act when a plaintiff seeks to obtain a statement of reasons from the Court of Appeal?

Records Act ( 6259, subd. (d)). (Crews v. Willows Unified School Dist. (2013) 217 Cal.App.4th 1368, 1379.) That provision, however, is a mandatory attorney fee provision in the event the plaintiff has brought a frivolous claim. ( 6259, subd. (d).) The Brown Act's attorney fee provision, however, is discretionary, which is why a statement of reasons is required so that the trial court's decision may be adequately reviewed. (Boyle v. City of Redondo Beach, supra, 70 Cal.App.4th at p. 1120.) The abuse of discretion standard is appropriate in this context.

"Discretionary decisions are subject to an abuse of discretion standard of review, and will not be reversed on appeal unless it appears that the court abused its discretion and a miscarriage of justice has resulted. [Citation .] ' "Discretion is abused whenever, in its exercise, the court exceeds the bounds of reason, all of the circumstances before it being considered. The burden is on the party complaining to establish an abuse of discretion, and unless a clear case of abuse is shown and unless there has been a miscarriage of justice a reviewing court will not substitute its opinion and thereby divest the trial court of its discretionary power." ' " (Silver v. Boatwright Home Inspection, Inc. (2002) 97 Cal.App.4th 443, 449, quoting Denham v. Superior Court (1970) 2 Cal.3d 557, 566.)