In what circumstances will a court award attorney fees to a plaintiff who has been found frivolous and prosecuted in bad faith?

4 Bond relies on West Coast Development v. Reed (1992) 2 Cal.App.4th 693, 3 Cal.Rptr.2d 790. In West Coast, a court awarded attorney fees under Code of Civil Procedure section 128.5, finding plaintiff's action frivolous and prosecuted in bad faith. The court of appeal reversed. Although the appellate court found the totality of circumstances supported the award, the trial court erred in issuing a written decision devoid of any statement of grounds for awarding attorney fees. (Id. at pp. 702-706, 3 Cal.Rptr.2d 790.)