According to the Second District Court of Appeal in the family law case of In Re Marriage of Rangell decided on September 28, 2023 the answer is YES! The Court of Appeal found that the husband had violated numerous family court orders for over two years and that the court’s imposition of sanctions pursuant to Family Code Family Code §271 was not abusive. In upholding the trial court’s imposition of $1000 a day sanction until the husband had complied with the court’s orders, the Court of Appeal stated:
The lesson here to [husband] is plain: he cannot repeatedly flout the court’s orders for years and expect to get away with it, when his conduct delayed [Wife’s] enjoyment of her share of community property and caused her to incur additional attorney fees and costs in enforcing the court’s orders. “‘Somewhere along the line, litigation must cease.’ [Citation.] [Husband] has yet to absorb this message,” warranting sanctions. (In re Marriage of Tharp (2010) 188 Cal.App.4th 1295, 1317–1318, 1320 [116 Cal. Rptr. 3d 375] [“When making the award, the family court shall consider [Husband’s] dilatory tactics … and the policy of imposing sanctions in an amount sufficient to deter future similar conduct.”].)
This is another recent case where the Court of Appeal has come down hard on parties who have repeatedly violated court orders. Though the case was decided under Family Code §271, the rationale is applicable to other civil cases.