California Codes

Cal. Probate Code § 3601 (2026)

✓ current as of May 2026
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(a)The court making the order or giving the judgment referred to in Section 3600, as a part thereof, shall make a further order authorizing and directing that reasonable expenses, medical or otherwise and including reimbursement to a parent, guardian, or conservator, costs, and attorney’s fees, as the court shall approve and allow therein, shall be paid from the money or other property to be paid or delivered for the benefit of the minor or person with a disability.

(b)The order required by subdivision (a) may be directed to the following:

(1)A parent of the minor, the guardian ad litem, or the guardian of the estate of the minor or the conservator of the estate of the person with a disability.

(2)The payer of any money to be paid pursuant to the compromise, covenant, or judgment for the benefit of the minor or person with a disability.

Notes of Decisions
Cited in 61 cases (46 in the last 5 years), 1996–2025 · leading case: Goncalves Ex Rel. Goncalves v. Rady Child.'s Hosp. San Diego, 865 F.3d 1237 (9th Cir. 2017).
Goncalves Ex Rel. Goncalves v. Rady Child.'s Hosp. San Diego, 865 F.3d 1237 (9th Cir. 2017). · cites it 13× “Although the Superior Court must issue an order “authorizing and directing” the payment of reasonable expenses, “including reimbursement to a parent, guardian, conservator, costs, and attorney’s fees,” Cal. Prob. Code § 3601 (a), and may order that the money be paid into a…”
Tapia v. Pohlmann, 98 Cal. Daily Op. Serv. 9366 (Cal. Ct. App. 1998). · cites it 4× “1 5 and Health and Safety Code section *1131 123982,* **** 6 the county asserts the court’s order reducing the requested amount was improperly based on a statute of general application involving minors’ compromises (Prob. Code, § 3601) 7 and a statute applicable only to MediCal…”
McLaughlin v. State Bd. of Educ., 99 Cal. Daily Op. Serv. 7991 (Cal. Ct. App. 1999). “(Prob. Code, § 3601.) In reversing the trial court’s order reducing the lien, the court noted that to the extent the statutes were in conflict, the more specific statute applicable to the subject matter would control.”
Gonzalez v. Chen, 197 Cal. App. 4th 881 (Cal. Ct. App. 2011). “” (Prob. Code, § 3601, subd. (a); see id., § 3600, subd.”
Sisco v. Cosgrove, Michelizzi, Schwabacher, Ward, 96 Cal. Daily Op. Serv. 9483 (Cal. Ct. App. 1996). “) Probate Code section 3601 provides that the court approving the compromise shall direct that an amount for reasonable expenses and attorney’s fees be paid from the settlement.”
Goncalves ex rel. Goncalves v. Rady Child.'s Hosp. San Diego, 65 F. Supp. 3d 985 (S.D. Cal. 2014). “As it is the state court’s responsibility to determine the reasonableness of any claim against Plaintiff’s settlement, see Cal. PRob.Code § 3601, an adjudication of Plaintiffs motion to expunge by this Court would necessarily “interfere with the probate proceedings” by removing…”
Fitzgerald v. Papa Murphy's Int'l, LLC (E.D. Cal. 2019). · cites it 3× “CAL. PROB. CODE § 3601; CAL FAM. CODE § 6602.”
John Doe v. Camp Pendleton & Quantico Hous., LLC (S.D. Cal. 2020). · cites it 3× “]” Cal. Prob. Code § 3601 . Jane Doe has declared under penalty of 8 perjury that, since the date the family moved into the subject residence, she has incurred 9 approximately $6,290.”
Crespo v. Hunterwood Tech. USA, LTD. (S.D. Cal. 2023). · cites it 3× “See Cal. Prob. Code § 3601 . Under California 5 law, the Court must evaluate the reasonableness of the settlement and determine whether 6 the compromise is in the best interest of the minor.”
Goettlich v. Kneller (S.D. Cal. 2024). · cites it 3× “See Cal. Prob. Code § 3601 (a) (“authorizing 7 and directing that reasonable expenses, medical or otherwise .”
Martinez v. Nienow (S.D. Cal. 2024). · cites it 3× “See Cal. Prob. Code § 3601 ; Cal. Rule of Ct.”
Rivett v. United States (E.D. Cal. 2023). · cites it 2× “Cal. Prob. Code § 3601 ; Cal. Fam. Code § 6602 .”
— Cal. Probate Code § 3601(a) — 3 cases
John Doe v. Camp Pendleton & Quantico Hous., LLC (S.D. Cal. 2020). “]” Cal. Prob. Code § 3601 . Jane Doe has declared under penalty of 8 perjury that, since the date the family moved into the subject residence, she has incurred 9 approximately $6,290.”
— Cal. Probate Code § 3601(b) — 1 case
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