Nash v. Aprea (2023) B322796 B322796; filed 10/3/23. ![[Files/CaseFiles/B322796.PDF]] [Opinion PDF](https://www.courts.ca.gov/opinions/archive/B322796.PDF) ## Rule excerpts Code of Civil Procedure section 685.040: contractual fee limits after merger into a judgment; enforcement costs must remain reasonable and necessary. > Thus, there need only be an award of contractually authorized fees to open the door to recovery of postjudgment fees as enforcement costs. We decline Aprea’s invitation to read into section 685.040 an additional requirement that there not only be an award of attorneys’ fees in the judgment “pursuant to” section 1033.5, subdivision (a)(10)(A) (that is, the judgment awarded fees based on an attorneys’ fees provision in a contract), but that any enforcement fees also be expressly authorized by the underlying contract. — Nash v. Aprea (2023) B322796, slip op., p. 11.