Marriage of J.C. and M.C. CA4/3

── Marriage of J.C. and M.C. CA4/3 ── Court: California Court of Appeal Date: April 17, 2026 Category: General Filed 4/17/26 Marriage of J.C. and M.C. CA4/3 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FOURTH APPELLATE DISTRICT DIVISION THREE In re the Marriage of J.C. and M.C. J.C., G065089 Respondent, (Super. Ct. No. 15D005137) v. OPINION M.C., Appellant. Appeal from postjudgment orders of the Superior Court of Orange County, Carmen R. Luege, Judge. Reversed and remanded. Motion to augment denied. Law Offices of Lisa R. McCall, Lisa R. McCall and Erica M. Barbero for Appellant. No appearance for Respondent.  Appellant M.C. (Wife) challenges the trial court’s denial of her request for appellate attorney fees, its appointment of a “special master,” and its order for co-parenting counseling in this marriage dissolution proceeding. We agree that the court erred in these rulings.1 The denial of fees was based on the incorrect premise that Wife’s prior appeal was groundless. The court’s sua sponte reference of matters to a “special master” was overbroad. And the court failed to make a required finding when it ordered co-parenting therapy. We reverse and remand.2 FACTS I. INITIAL PROCEEDINGS AND JUDGMENT Respondent J.C. (Husband) petitioned to dissolve the parties’ marriage in 2012. The family lived in the Bay Area but Wife later moved to Orange County with the parties’ son. Husband initially followed them but later moved away after he lost his job. The trial court (then-Judge Maurice Sanchez) held a trial on permanent custody and visitation arrangements in June 2019. In a thorough minute order issued after trial, the court detailed its findings and its visitation and custody orders. It granted Wife sole legal custody but stated 1 This court’s opinion in the prior appeal included only the parties’ initials to protect the privacy of their minor child. (See Cal. Rules of Court, rule 8.90(b)(1) [children in Fam. Code proceedings], (11) [persons whose names may identify protected person].) We do the same here. 2 We need not address Wife’s contention that the trial court erred by denying her motion to vacate the challenged orders. Nor do we address her claim that the court erred by failing to rule on other requests she had made— those requests remain pending before the court and will be addressed in due course on remand. 2 that Husband could raise the issue again when he returned to Orange County. The court directed Wife’s counsel to prepare a formal judgment. It later ruled on certain financial issues that had previously been reserved. Wife, who was now self-represented, submitted a proposed judgment on the mandatory FL-180 form in 2021. She checked the box indicating the proceeding had been “Contested.” She included a typed 15-page attachment detailing the procedural history of the case, along with the court’s findings and rulings on disputed issues. The last page of the attachment stated: “THE FOREGOING IS AGREED TO BY:” and included signature lines for both parties. Wife signed the document; Husband did not. Above the judge’s signature line, the attachment stated: “APPROVED AS C