California, United States of America
The following excerpt is from Park Plaza Ii, Ltd. v. Am. Bankers Insuranc Co., G049334 (Cal. App. 2015):
202 Cal.App.4th 1483, 1488-1489 [order awarding attorney fees must be reversed when underlying judgment supporting award is reversed]; Center for Biological Diversity v. County of San Bernardino (2010) 188 Cal.App.4th 603, 613, fn. 4 ["the appellate court's reversal of the judgment on the merits extinguishes the order on fees" even if the losing party failed to appeal fee award (original italics)].)
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