In Voelkle v. Sisemore, 1959 OK 51, 338 P.2d 1080, the plaintiffs/mortgagees filed a foreclosure action against the principal defendant/mortgagor. The plaintiffs/mortgagees also named incidental defendants who claimed some right, title or interest in the mortgaged property. Id. Two incidental defendants filed answers and cross-petitions asserting lien claims against the property and "praying that their claimed liens be adjudged paramount to all others, including the mortgage lien of the plaintiffs." Id. The trial court determined the plaintiffs/mortgagees' lien had first priority and the incidental defendants' liens had lesser priority. Id. Judgment was entered against the mortgagor, which included an award of attorney fees. Id. In addition to the attorney fees recovered from the principal defendant/mortgagor, plaintiffs/mortgagees filed an application for attorney fees against the two incidental defendants based on 42 O.S.1951 176. Id. at 1081-82. The application for attorney fees against the incidental defendants was denied, and the plaintiffs/mortgagees appealed. The issue on appeal in Voelkle was whether "incidental defendants in mortgage foreclosure who do more than defend their lien, but affirmatively seek by cross-petition and evidence to establish their lien against the plaintiff's interest in the land have subjected themselves to attorney's fees assessed as costs if unsuccessful as against such plaintiffs on such issue." Id. at 1082. The Supreme Court of Oklahoma set forth the general rule that attorney fees are not allowed against incidental defendants: "Statutes of this character are primarily intended to reimburse the principal parties to the cause, when forced to resort to the courts to enforce or defend their rights. In foreclosure cases, it is common knowledge that there are usually numerous defendants, brought in with the principal one, in order to clear the title of outstanding equities, liens, and claims. However, we think the practice observed by the courts generally, if not universally, is to allow attorney's fees under such statutes against the principal defendant debtor, and against the particular res, the subject of the litigation, and not against other incidental defendants, brought in for the purposes above suggested. We do not think the fact that some of these incidental defendants may resist in good faith should, in the absence of some clear statutory provision, change the general rule. The plaintiff's purpose in coming into court was to foreclose its mortgage and convert its lien or conditional estate into an absolute estate. The clearing off of junior liens, claims, and equities is a part of its task, and under the statute in question plaintiff is allowed a reasonable attorney's fee, we think, against the principal defendant and the res, whether that defendant defends or defaults, and we do not understand such reasonable fee to be measured alone by the services necessary to bringing the suit and the prosecution of the matter against the principal defendant." Id. The Supreme Court rejected the plaintiffs/mortgagees' argument "that the competing lienholders cannot be considered 'incidental defendants' within the general rule, because of the force and means they used in establishing and enforcing their claimed liens." Id.