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Marriage of Howse
In this child custody dispute, petitioner Ginger Howse appeals from the trial courts award of $3,500 in attorney fee sanctions to her former husband Marc. She contends the sanction was unjustified by the facts and uninformed by any consideration of the parties relative financial statements. Court agree only with the second contention, and order the matter remanded for the trial court to follow the mandate of Family Code section 271, subdivision (2), that it take into consideration all evidence concerning the parties incomes, assets, and liabilities and consider whether imposing a sanction would impose an unreasonable financial burden.

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