People v. Edwards (2023) C094784
C094784; filed 3/7/23.
![[Files/CaseFiles/C094784.PDF]]
[Opinion PDF](https://www.courts.ca.gov/opinions/archive/C094784.PDF)
## Rule excerpts
Code of Civil Procedure section 177.5: written findings and the cap per separate violation. Daily sanctions require findings of separate violations; they are not automatic.
> Section 177.5 provides an order imposing sanctions must satisfy two requirements: (1) it must be in writing; and (2) it must “recite in detail the conduct or circumstances justifying the order.” (§ 177.5.)
— People v. Edwards (2023) C094784, slip op., p. 13.
> Since no evidence of a contrary intent clearly appears, we presume the Legislature intended to limit sanctions under section 177.5 to $1,500, unless separate violations of a court order are committed, in which case the violator could be fined up to $1,500 for each separate violation. In this case, however, the trial court made no findings on whether DSH committed separate violations of a court order on each day beyond the court’s deadline that it failed to admit a defendant. We will thus remand this case to the trial court to make such findings in the first instance.
— People v. Edwards (2023) C094784, slip op., p. 21.