What is the test for a cause of action for malicious prosecution based on an order to show cause in a family law proceeding?

Finally, plaintiff cites Chauncey v. Niems (1986) 182 Cal.App.3d 967, 227 Cal.Rptr. 718, which upheld causes of action for malicious prosecution based on orders to show cause in a family law proceeding. The court offered three reasons for its ruling: (1) an order to show cause re contempt exposed the plaintiff to criminal sanctions; (2) it required him to retain counsel, appear in court and respond to lengthy interrogatories; and (3) "[w]hile the order may or may not have had an 'independent existence,' it nonetheless [224 Cal.App.3d 276] bore the indisputable earmarks of an adversarial proceeding. Most significantly, it incurred expenses, provoked psychological trauma, and required expenditure of time and effort to defend fully sufficient for us to find it the sort of proceeding upon which plaintiff could base a malicious prosecution action." (Id., pp. 975-976, 227 Cal.Rptr. 718.)