Robert J. v. Catherine D. (2009) 171 Cal.App.4th 1500
Holding
A motion for sanctions under FC §3027.1 (false accusations of child abuse during custody proceedings) must be filed on or before the earlier of: (a) 60 days after the judgment or order exonerating the moving party from the allegations is served, or (b) 180 days from the entry of that judgment or order. This was an issue of first impression in California.
Relevance to this matter
Critical timing authority for any FC §3027.1 sanctions effort following a CFWB closure / formal exoneration finding. Calendar discipline matters: the 60-day-from-service / 180-day-from-entry deadline is hard. Pair with FC §3027.1 - Sanctions For False Allegations of Child Abuse and the CFWB Interview Memorandum at 2026-04-22 - Meeting - CFWB Interview when planning the post-closure response.