In In re Marriage of Hatch (1985) 169 Cal.App.3d 1213, the trial court summarily denied the wife's motion for attorney fees pendente lite. The appellate court reversed, noting that it was an abuse of discretion to deny the motion without considering the needs of the requesting party and the other party's ability to pay. (Id. at p. 1216.) In that case the evidence demonstrated that the wife had no income other than spousal and child support. In addition she stated that she had been unable to pay her attorney any fees. (Id. at p. 1217.) The appellate court explained that it was an abuse of discretion to deny fees where one spouse demonstrated an inability to pay his or her attorney fees while showing the other spouse had the ability to pay. (Id. at p. 1219.) In short, the trial court denied wife's request for pendente lite attorney fees after telling her counsel, "Spare yourself that kind of motion. I never grant attorney fees around here . . . because . . . in the family-law area an attorney normally carries the client until the time of trial." (Hatch, supra, 169 Cal.App.3d at p. 1217.) Unsurprisingly, the appellate court held that the trial court's failure to exercise discretion in denying wife's motion for pendente lite attorney fees was an abuse of discretion. (Id. at p. 1222.)