April 3, 2026
Court of Appeal, Second Appellate District, Division Six
The Rule of In re Marriage of Charles and Julie Ann Bowman is that trial courts retain discretion to consider Family Code factors including the losing party's ability to pay when determining the amount of attorney's fees under a prevailing party clause in a marital settlement agreement, under circumstances where the MSA contains a general attorney's fees provision without specific limitations on the court's consideration of equitable factors.
February 9, 2026
Court of Appeal of the State of California, Second Appellate District, Division Eight
The Rule of In re Reyna R. is that a juvenile court errs in ordering a parent to pay for professional visitation monitoring without first considering the parent's ability to pay or reasonable alternatives when the parent raises a timely objection based on financial inability, under circumstances where the parent objects to professional monitoring costs at the exit order hearing.
2/17/26
Court of Appeal, Fourth Appellate District, Division One
The Rule of People v. Gutierrez is that a Governor's state of emergency proclamation is subject to independent legal interpretation by courts, not jury determination, and when a proclamation limits emergency zones to specific "high hazard areas" to be identified by state agencies rather than declaring a statewide emergency, the prosecution must prove the crime occurred within those specifically identified areas, under circumstances where the proclamation's plain language directs agencies to identify particular zones rather than declaring the emergency exists throughout the entire state.