Catherine Lederle v. Stevan Spivey

Summary

The court held that the trial court properly awarded appellate attorney's fees under the bad-faith exception to the American rule because its factual findings sufficiently established both that the defendant's appellate claims were objectively without color and that he subjectively knew they lacked merit. The court also upheld the $30,000 amount of the award, concluding that the trial court acted within its discretion after considering the fee evidence and reducing the requested amount. The judgment reversing the fee award was therefore reversed, with instructions to affirm the trial court.