California Supreme Court Watch

#26-49 Honchariw v. PMF CA REIT, LLC, S295127. (B337927; 117 Cal.App.5th 827; Los Angeles County Superior Court; 21STCV25191.) Petition for review after the Court of Appeal affirmed in part and reversed in part the judgment in a civil action and remanded with directions. This case presents the following issues: (1) Under what circumstances, if any, can a litigant recover attorney fees as a prevailing party for work performed by their attorney-spouse on a joint claim or defense? (2) Do Code of Civil Procedure sections 1021 and 1033.5 authorize self-represented attorneys to recover fees under a contractual attorney’s fees clause? (See Musaelian v. Adams (2009) 45 Cal.4th 512; Trope v. Katz (1995) 11 Cal.4th 274.)

Petition for review granted: 3/25/2026

See the Court of Appeal Opinion.