In Bank of Idaho v. Pine Avenue Associates (1982) 137 Cal. App. 3d 5, the Court of Appeal suggested in dicta that an award of fees to a plaintiff successful in an interim ruling (and, by analogy, a denial of fees incurred by the prevailing party in a prior, unsuccessful appeal) would be proper after final judgment is rendered, even if the defendant ultimately prevails. (Id. at p. 17.) This dicta has been roundly criticized. Under the Bank of Idaho approach, a defendant whose motion for summary judgment is denied by the trial court would have to pay the fees plaintiff incurred in opposing the motion even if the defendant goes on to win the case; there is no real distinction between that scenario and a case such as the one at bench where the settlement of an interim issue, such as summary judgment, requires a side trip to the Court of Appeal. It would be both impractical and unfair to ask the trial courts to review all the procedural rulings in a case before deciding who is entitled to what fees. A party who wins an outright victory should recover all his fees without offset for the fees incurred by the other party.