Can a plaintiff representing himself in propria persona be awarded attorney fees under Code of Civil Procedure section 128.5?

[52 Cal.App.4th 915] An analogous situation arises for litigants representing themselves in propria persona. Following Bergman's reasoning, an argument could be made and was made in Abandonato v. Coldren (1995) 41 Cal.App.4th 264, 267, 48 Cal.Rptr.2d 429, that respondents "who [were] attorneys, [could not] be awarded attorney fees [under Code of Civil Procedure section 128.5] since they represented themselves in the action and neither paid, nor incurred any liability to pay, attorneys

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The Fourth Appellate District was not persuaded and found "Trope inapposite." (Abandonato v. Coldren, supra, 41 Cal.App.4th at p. 268, 48 Cal.Rptr.2d 429.) That court found the "considerations which powered Trope are not present when a court awards sanctions under Code of Civil Procedure section 128.5. To begin with, sanctions under that section are not limited to court costs and attorney fees but include those reasonable expenses 'directly related to and in furtherance of the litigation.' " (Ibid.) The court further explained there is "nothing oppressive or one-sided in awarding attorney fees under Code of Civil Procedure section 128.5 to an attorney who litigates in propria persona" and it held "sanctions under section 128.5 may be awarded in favor of both a self-representing attorney and a nonattorney pro se litigant." (Id. at pp. 268-269, 48 Cal.Rptr.2d 429.)