Trial court properly assessed contribution to attorney fees based on continuing overtrial tactics on appeal. When appellate court finds that issues on appeal are frivolous, circuit court can conduct a hearing to sanction a party if warranted.
In this case, attorney billing records are protected by attorney-client privilege due to the detailed descriptions of the nature of the legal services. Holding is limited to particular facts in this case and not a broad rule that all attorney billing records are protected.
Trial court had authority under Wis. Stat. §767.23(3)(a) to enter a judgment for fees where the attorney moved to withdraw, regardless of when or if the client retains another attorney to replace the withdrawing attorney.
Circuit court erred by requiring father to pay 50% of GAL fees in a Wis. Stat. §767.242(5)(b)1.b action.
Award of attorney fees is mandatory for an action to enforce a physical placement order.
No error in awarding attorney fees based on overtrial where court found the attorney asked irrelevant questions even after a warning from the court. Overtrial can also be a basis to order one party to pay all of the GAL fees.
Request for de novo review of adverse FCC ruling was not overtrial.
Overtrial award affirmed where mother filed an action in Illinois since Wisconsin has had continuing jurisdiction and the two actions were intrinsically related.
Overtrial award affirmed where mother filed an action in Illinois since Wisconsin has had continuing jurisdiction and the two actions were intrinsically related.