Lanyi v. Goldblum

In Lanyi v. Goldblum (1986) 177 Cal. App. 3d 181, an action on a contract providing for recovery of attorney fees by the prevailing party, the court held that attorney fees are available to a party who prevails by a section 998 compromise settlement silent as to costs and fees. "The combined reasoning of Rappenecker and Folsom compels the conclusion that attorney fees authorized by section 1717 are available to a party who prevails by a section 998 compromise settlement that is silent as to costs and fees." ( Id. at p. 187.)