Is a beneficiary of a trust liable for attorney fees if they successfully challenge the trustee's conduct?

"Trust beneficiaries must ordinarily pay their own attorney fees in challenging the trustee's conduct, even when they are successful." (Leader v. Cords (2010) 182 Cal.App.4th 1588, 1595.) An exception to this is found in section 17211, subdivision (b), which states: "If a beneficiary contests the trustee's account and the court determines that the trustee's opposition to the contest was without reasonable cause and in bad faith, the court may award the contestant the costs of the contestant and other expenses and costs of litigation, including attorney's fees, incurred to contest the account. The amount awarded shall be a charge against the compensation or other interest of the trustee in the trust. The trustee shall be personally liable . . . for any amount that remains unsatisfied." (Second italics added, original italics omitted.)

"[R]easonable cause to oppose a contest of an account requires an objectively reasonable belief, based on the facts then known to the trustee, either that the claims are legally or factually unfounded or that the petitioner is not entitled to the requested remedies." (Uzyel v. Kadisha (2010) 188 Cal.App.4th 866, 927.) In Uzyel, the court denied attorney fees to the objector because the trustee defeated some of the objector's claims, showing the trustee had reasonable cause. (Id. at pp. 927-928.)