What is the test for imposing a sanction including an order requiring an attorney for one party to pay attorney fees for an opposing party?

In an analogous situation, wherein the court noted there was no legislative authorization for imposition of a sanction including an order requiring an attorney for one party to pay attorney fees for an opposing [22 Cal.3d 643] party when the first party refused to comply with particular discovery orders, the court held: "Every court has power 'to compel obedience to its judgments, orders, and process' in an action or proceeding pending before it, and to use all necessary means to carry its jurisdiction into effect, even if those means are not specifically pointed out in the code." (Fairfield v. Superior Court (1966) 246 Cal.App.2d 113, 120, 54 Cal.Rptr. 721, 726.)

In another case in which sanctions requiring payment of money to an opposing party were upheld, the court stated: "Every court has the inherent power to regulate the proceedings of matters before it and to effect an orderly disposition of the issues presented. (Citations.) Sanctions are expressly provided for in some situations (citations) but sanctions have also been approved in situations which are not expressly covered by statute or court rules. . . . (P) . . . Although no direct order of the trial court was disobeyed, the facts support the view that the time of both the court and of opposing counsel was wasted. (P) The exercise of the court's inherent power to provide for the orderly conduct of the court's business is a matter vested in the sound legal discretion of the trial court. Such a decision is subject to reversal only where there has been an abuse of that discretion." (Santandrea v. Siltec Corp. (1976) 56 Cal.App.3d 525, 529-530, 128 Cal.Rptr. 629, 632.)