Heather Farms Homeowners Assn. v. Robinson

In Heather Farms Homeowners Assn. v. Robinson (1994) 21 Cal.App.4th 1568, the court held that for purposes of determining the prevailing party in a Civil Code section 1354 suit brought to enforce governing documents of common interest developments, trial courts should avoid adopting a rigid interpretation of the term "prevailing party," and instead should "analyze which party . . . prevailed on a practical level," including finding that no party prevailed for purposes of awarding attorney's fees even though there might be a prevailing party for purposes of a cost award under the general cost provisions found in Code of Civil Procedure section 1032, subdivision (a) (4) (which states that "prevailing party" includes, among other litigants, a defendant in whose favor a dismissal is entered). ( Id. at p. 1574.) The court observed that California courts have "uniformly rejected" the notion that "a litigant who prevails under the cost statute is necessarily the prevailing party for purposes of attorney fees." ( Id. at p. 1572.) The court also held that reviewing courts should affirm the trial court's "prevailing party" determination absent an abuse of discretion. ( Id at p. 1574.)