Can a contractual attorney's fee provision allow the prevailing party to recover attorney's fees in a non-contractual or tort action?

If a contractual attorney's fee provision is phrased broadly enough, the prevailing party in a dispute may recover attorney's fees in connection with noncontractual or tort claims. (Santisas v. Goodin (1998) 17 Cal.4th 599, 608.) For example, courts have held that an attorney's fee provision that provides for fees in any action arising from or relating to the contract is broad enough to encompass recovery of attorney's fees for tort claims. (Id. at p. 603 [holding that a provision authorizing fees in any legal action

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