Midwife v. Bernal

In Midwife v. Bernal (1988) 203 Cal.App.3d 57, 64, the court rejected the argument that imposing monetary sanctions on an indigent litigant necessarily violated the litigant's rights. "A litigant proceeding in forma pauperis is held to the same standard of conduct in conducting litigation as any other party, and the power of the court to impose monetary sanctions for frivolous or harassing conduct or refusal to permit discovery is well established. . . . Monetary sanctions are always available to discourage abusive or recalcitrant behavior provided proper findings are made and appropriate procedures are followed." (Midwife v. Bernal, at p. 65.)