California, United States of America
The following excerpt is from Stark v. Ortiz, A153680 (Cal. App. 2019):
4. The bench officer who issued the fee award was not the same bench officer who presided over the trial. Plaintiffs argue that "when, as here, the fee order under review was rendered by a judge other than the trial judge, we may exercise ' "somewhat more latitude in determining whether there has been an abuse of discretion than would be true in the usual case." ' " (Center for Biological Diversity v. County of San Bernardino (2010) 188 Cal.App.4th 603, 616.) A less deferential standard of review would not change our conclusion.
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