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]]