What is the test for overturning an award for attorney fees?

Finally, we turn to our decision in Paul v. Schoellkopf (2005) 128 Cal.App.4th 147 (Paul), where we reversed an attorney fee award for the prevailing seller of real property in his action against the buyer. The parties executed three documents as part of their transactionthe purchase agreement, an addendum, and escrow instructions. Only the escrow instructions included an attorney fee provision, which allowed the escrow to recover its reasonable attorney fees incurred in the event the parties failed to pay the escrow's fees or expenses. (Paul, at pp. 150-151.)

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