In Bidna v. Rosen (1993) 19 Cal.App.4th 27, the court considered prior precedent regarding malicious prosecution actions arising from dissolution proceedings, and adopted a brightline rule prohibiting all malicious prosecution actions arising out of family law proceedings. (Id. at p. 37.) "The arguments for a bright line rule are several and substantial. First, family law cases have a unique propensity for bitterness. . . . Second, family law courts have the unique ability to swiftly discourage litigious nonsense at its source by means of attorney fee awards which are intended as a sanction against a party's conduct. . . .Third, family law remedies require a special sensitivity and flexibility; allowing separate malicious prosecution actions in the wake of unsuccessful attempts to obtain certain remedies may have a chilling effect on the ability to obtain those remedies by . . . increasing the risk of asking for them. . . . Finally, . . . there is the impact of separate malicious prosecutions . . . on lawyers' malpractice insurance premiums. . . ." (Bidna, supra, 19 Cal.App.4th at p. 35) The Court explained: "Abuse of process is not just another name for malicious prosecution. Simply filing or maintaining a lawsuit for an improper purpose (such as might support a malicious prosecution cause of action) is not abuse of process. Malicious prosecution and abuse of process are distinct. The former concerns a meritless lawsuit (and all the damage it inflicted). The latter concerns the misuse of the tools the law affords litigants once they are in a lawsuit (regardless of whether there was probable cause to commence that lawsuit in the first place). Hence, abuse of process claims typically arise for improper or excessive attachments . . . or improper use of discovery . . . ."