What is the test for appeal against an award of attorney fees, costs and prejudgment interest?

California, United States of America


The following excerpt is from Medina v. S. Coast Car Co., 15 Cal.App.5th 671, 223 Cal.Rptr.3d 566 (Cal. App. 2017):

Because defendants' myriad challenges on appeal to the award of attorney fees, costs and prejudgment interest are limited to the issue of entitlement, as opposed to the their amount, we have no reason to review the reasonableness of such an award. Nonetheless, based on our own independent review of the record, it is clear the court properly exercised its discretion when it made this award. (See Ketchum v. Moses (2001) 24 Cal.4th 1122, 1133, 1138, 104 Cal.Rptr.2d 377, 17 P.3d 735 [noting a trial court has broad discretion in deciding attorney fee issues]; Cates v. Chiang (2013) 213 Cal.App.4th 791, 820821, 153 Cal.Rptr.3d 285 [noting an attorney fee award will not be reversed unless a reviewing court is "convinced" the ruling is "clearly wrong" and further noting the general rule that "[t]rial judges are ... in the best position to assess the value of the professional services provided in their courts"].)

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