California Court of Appeal

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In re Marriage of Turkanis and Price, B229482

Orders granting husband's motion to expunge the wife's attorneys' family law attorney's real property liens (FLARPL's) and offsetting the fee award for unreasonable litigation conduct are affirmed, where: 1) although the court's award of the liened property to husband as his separate property did not automatically extinguish the liens, Family Code section 2034 permitted the court to expunge the FLARPL's; and 2) the trial court did not abuse its discretion in reducing the attorney's fee award for sanctions based on the totality of the circumstances, including wife's litigation conduct.

Appellate Information

  • Decided 01/30/2013
  • Published 01/30/2013




  • California Court of Appeal