Santandrea v. Siltec Corp

In Santandrea v. Siltec Corp. (1976) 56 Cal.App.3d 525, the Court interpreted the above code section as permitting a trial court award of sanctions. There, after summary judgment had been granted the losing party moved for reconsideration. The motion was denied and the court ordered the moving party to pay sanctions of $ 100 because the motion to reconsider was frivolous. On appeal, this division upheld the award of sanctions, stating: "Every court has the inherent power to regulate the proceedings of matters before it and to effect an orderly disposition of the issues presented. ( Code Civ. Proc., 128 case citations omitted). Sanctions are expressly provided for in some situations examples omitted but sanctions have also been approved in situations which are not expressly covered by statute or court rules. In the case of Fairfield v. Superior Court (1966) 246 Cal.App.2d 113 . . ., the court upheld '"sanctions of $ 100.00 as to each defendant for unnecessary legal work required of plaintiff . . . ."'" (Id., at p. 529.)