In the case of **In re Marriage of Blake and Langer**, the Second District affirmed that the trial court had jurisdiction to impose sanctions under [[Cal. Fam. Code § 271]] against the wife's brother, even though the husband had dismissed his joinder complaint against him prior to the final order. The sanctions were imposed as a result of the conduct of the wife and her brother in frustrating the settlement, and therefore, the court's authority to impose sanctions against the brother remained intact. ![[B311966.PDF]] <!-- citation-library:start --> ## Citation reference Blake & Langer, In re Marriage of (2022) 85 Cal.App.5th 300, 301 Cal.Rptr.3d 228 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end -->