private attorney general doctrine in California

2024Statutory Criteria Section 1021.5 provides in part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement, or of enforcement by one public entity against another public entity, are such as to make the award appropriate, and (c) such fees should

2020(Whitley, at p. 1214.) The third factor "does not apply where, as here, a plaintiff's action produces no monetary recovery." (Weiss v. City of Los Angeles (2016) 2 Cal.App.5th 194, 218 , citing Woodland Hills Residents Assn., Inc. v. City Council (1979) 23 Cal.3d 917 , 934–935.) The fundamental purpose of the private attorney general doctrine is to encourage parties to bring lawsuits that effectuate a strong public policy and confer benefits to a broad class of citizens, by awarding substantial attorney's fees to those who successfully bring such suits.

2022Section 1021.5 Attorney Fees: Legal Standards and Standard of Review “ ‘Section 1021.5 codifies the private attorney general doctrine the Supreme Court adopted in Serrano v. Priest (1977) 20 Cal.3d 25 . . . . [Citation.] “ ‘ “The doctrine rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of the fundamental public policies embodied in constitutional or statutory provisions, and that, without some mechanism authorizing the award of attorney fees, private actions to enforce such important public policies will as a practical matter frequently be i

2021In addition to seeking monetary sanctions under section 177.5, Rudisill and Hawk filed a motion for attorneys’ fees under section 575.2, the statute governing failure to comply with local rules, and the private attorney general doctrine articulated in Serrano v. Priest (1977) 20 Cal.3d 25 , seeking over $141,000 in attorneys’ fees.

2025Entitlement to Attorney Fees As noted, the trial court awarded attorney fees under section 1021.5, which codifies the private attorney general doctrine of fee recovery (Press v. Lucky Stores, Inc. (1983) 34 Cal.3d 311, 317 ).

2014(Baggett v. Gates (1982) 32 Cal.3d 128, 142-143 [ 185 Cal.Rptr. 232 , 649 P.2d 874 ].) Although this standard is deferential, a court abuses its discretion “ ‘where no reasonable basis for the action is shown. [Citation.]’ ” (Westside Community for Independent Living, Inc. v. Obledo (1983) 33 Cal.3d 348, 355 [ 188 Cal.Rptr. 873 , 657 P.2d 365 ].) Determination of the proper amount of the award under section 1021.5 is within the trial court’s discretion, but the ultimate award “must still bear some reasonable relationship to the lodestar figure and to the purpose of the private attorney general

2026(See Luckett, at p. 926.) But no published opinion has suggested section 1021.5 provides a basis for an attorney fee award in the event a vexatious litigant dismisses an action before a court has ordered it to furnish security. “ ‘Section 1021.5 codifies California’s version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.’ ” (City of Oakland v

2019Statutory Framework and Standards of Review Recently, in City of Oakland v. Oakland Police & Fire Retirement System (2018) 29 Cal.App.5th 688 , 240 Cal.Rptr.3d 571 ( Oakland PFRS ), we summarized the underlying purpose of section 1021.5 as follows: " ' Section 1021.5 codifies California's version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.

2023Code, § 52, subd. (a).) The trial court “possesses discretion to determine the amount of the fees, but not their entitlement.” (Engel v. Worthington (1997) 60 Cal.App.4th 628, 632 .) “ ‘The Legislature adopted section 1021.5 as a codification of the private attorney general doctrine of attorney fees developed in prior judicial decisions. [Citation.] Under this section, the court may award attorney fees to a “successful party” in any action that “has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary,

2020DISCUSSION “The Legislature adopted section 1021.5 as a codification of the private attorney general doctrine of attorney fees developed in prior judicial decisions.” (Maria P. v. Riles (1987) 43 Cal.3d 1281, 1288 .) Section 1021.5 provides: “Upon motion, a court may award attorneys’ fees to a successful party against one or more 3 Villarreal alternatively sought an award of $7,500 in attorney fees under Government Code section 800.

2026Legal framework “An important exception to the American rule that litigants are to bear their own attorney fees is found in [S]ection 1021.5,” which “‘codifi[es] . . . the private attorney general doctrine of attorney fees developed in prior judicial decisions. [Citation.]’” (Graham v. DaimlerChrysler Corp. (2004) 34 Cal.4th 553, 565 , fn. omitted.) Section 1021.5 provides, in relevant part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public int

2024Statutory Criteria Section 1021.5 provides in part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement, or of enforcement by one public entity against another public entity, are such as to make the award appropriate, and (c) such fees should

2021In Serrano v. Unruh (1982) 32 Cal.3d 621 , the California Supreme Court held that the private attorney general doctrine “will often be frustrated, sometimes nullified, if awards are diluted or dissipated by lengthy, uncompensated proceedings to fix or defend a rightful fee claim.

2006As Graciano acknowledges, both Beaty, supra, 222 F.3d 607 and Vo, supra, 79 Cal.App.4th 440 , as well as Serrano IV, supra, 32 Cal.3d 621 , on which Vo relies, are cases in which the court addressed attorney fees awards under permissive statutory provisions—the FEHA (Beaty and Vo) and statutes embodying the private attorney general doctrine as in Code of Civil Procedure section 1021.5 (Serrano IV). 8 (Beaty, supra, 222 F.3d at p. 609 ; Vo, supra, 79 Cal.App.4th at p. 442; Serrano IV , at pp. 632-633.) Because of the underlying public policies behind these statutes, the courts addressing them h

2026The Private Attorney General Doctrine The private attorney general doctrine refers to the doctrine allowing awards of attorney fees “to those who by litigation secure benefits for a broad class of 11 individuals by effectuating a strong public policy.” (Gray v. Don Miller & Associates, Inc. (1984) 35 Cal.3d 498, 505 .) “The fundamental objective of the private attorney general doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.” (Vargas v. City of Salinas (2011) 200 Cal.App.4th 1331, 1339 .) The doctri

2018Attorney Fees It is axiomatic that parties in litigation generally pay their own attorney fees. ( Gray v. Don Miller & Associates, Inc. (1984) 35 Cal.3d 498 , 504, 198 Cal.Rptr. 551 , 674 P.2d 253 .) Code of Civil Procedure section 1021.5 is an exception to this rule, as it codifies the private attorney general doctrine and acts as an incentive to pursue " ' "public interest-related litigation that might otherwise have been too costly to bring." ' " ( Save Our Heritage Organisation v. City of San Diego (2017) 11 Cal.App.5th 154 , 159, 217 Cal.Rptr.3d 360 ( Save Our Heritage ).) *953 Code of Ci

2014(Baggett v. Gates (1982) 32 Cal.3d 128, 142-143 [ 185 Cal.Rptr. 232 , 649 P.2d 874 ].) Although this standard is deferential, a court abuses its discretion “ ‘where no reasonable basis for the action is shown. [Citation.]’ ” (Westside Community for Independent Living, Inc. v. Obledo (1983) 33 Cal.3d 348, 355 [ 188 Cal.Rptr. 873 , 657 P.2d 365 ].) Determination of the proper amount of the award under section 1021.5 is within the trial court’s discretion, but the ultimate award “must still bear some reasonable relationship to the lodestar figure and to the purpose of the private attorney general

2014(Baggett v. Gates (1982) 32 Cal.3d 128, 142-143 [ 185 Cal.Rptr. 232 , 649 P.2d 874 ].) Although this standard is deferential, a court abuses its discretion “ ‘where no reasonable basis for the action is shown. [Citation.]’ ” (Westside Community for Independent Living, Inc. v. Obledo (1983) 33 Cal.3d 348, 355 [ 188 Cal.Rptr. 873 , 657 P.2d 365 ].) Determination of the proper amount of the award under section 1021.5 is within the trial court’s discretion, but the ultimate award “must still bear some reasonable relationship to the lodestar figure and to the purpose of the private attorney general

2017Appellants primarily rely on Norberg v. California Coastal Com. (2013) 221 Cal.App.4th 535 , 164 Cal.Rptr.3d 440 , in which a property owner "sought to invalidate permit conditions affecting planned residential improvements on his privately owned oceanfront property." The court acknowledged that "the proper application of statutory language ... is an important right," but rejected the proposition that "the private attorney general doctrine was designed to reward plaintiffs who, in pursuit of their own interests, just happened to bring about the enforcement of a statute that benefits the public

2017Appellants primarily rely on Norberg v. California Coastal Com. (2013) 221 Cal.App.4th 535 , 164 Cal.Rptr.3d 440 , in which a property owner "sought to invalidate permit conditions affecting planned residential improvements on his privately owned oceanfront property." The court acknowledged that "the proper application of statutory language ... is an important right," but rejected the proposition that "the private attorney general doctrine was designed to reward plaintiffs who, in pursuit of their own interests, just happened to bring about the enforcement of a statute that benefits the public

2025Finally, the Honchariws argue they are entitled to attorney fees under section 1021.5, which codifies the private attorney general doctrine and encourages “suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.” (Robinson v. City of Chowchilla (2011) 202 Cal.App.4th 382, 390 .) According to the Honchariws, section 1021.5 does not prohibit awarding fees to attorney-litigants.

2024Finally, the Honchariws argue they are entitled to attorney fees under section 1021.5, which codifies the private attorney general doctrine and encourages “suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.” (Robinson v. City of Chowchilla (2011) 202 Cal.App.4th 382, 390 .) According to the Honchariws, section 1021.5 does not prohibit awarding fees to attorney-litigants.

2010Gallo v. Acuna (1997) 14 Cal.4th 1090, 1115 [ 60 Cal.Rptr.2d 277 , 929 P.2d 596 ] (Acuna).) 15 Code of Civil Procedure section 1021.5 “is a codification of the private attorney general doctrine adopted by the California Supreme Court.” (County of Colusa v. California Wildlife Conservation Bd. (2006) 145 Cal.App.4th 637, 647 [ 52 Cal.Rptr.3d 1 ].) Section 1021.5 *497 provides in relevant part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public in

2010Gallo v. Acuna (1997) 14 Cal.4th 1090, 1115 [ 60 Cal.Rptr.2d 277 , 929 P.2d 596 ] (Acuna).) 15 Code of Civil Procedure section 1021.5 “is a codification of the private attorney general doctrine adopted by the California Supreme Court.” (County of Colusa v. California Wildlife Conservation Bd. (2006) 145 Cal.App.4th 637, 647 [ 52 Cal.Rptr.3d 1 ].) Section 1021.5 *497 provides in relevant part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public in

2019SECTION 1021.5 "The Legislature adopted section 1021.5 as a codification of the private attorney general doctrine of attorney fees developed in prior judicial *980 decisions." ( Maria P. v. Riles (1987) 43 Cal.3d 1281 , 1288, 240 Cal.Rptr. 872 , 743 P.2d 932 .) "[T]he fundamental objective of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases." ( Id. at p. 1289, 240 Cal.Rptr. 872 , 743 P.2d 932 .) "Due to the burdens imposed on public agencies, adequate government enforcement of the laws is not alw

2019SECTION 1021.5 "The Legislature adopted section 1021.5 as a codification of the private attorney general doctrine of attorney fees developed in prior judicial *980 decisions." ( Maria P. v. Riles (1987) 43 Cal.3d 1281 , 1288, 240 Cal.Rptr. 872 , 743 P.2d 932 .) "[T]he fundamental objective of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases." ( Id. at p. 1289, 240 Cal.Rptr. 872 , 743 P.2d 932 .) "Due to the burdens imposed on public agencies, adequate government enforcement of the laws is not alw

2014(Baggett v. Gates (1982) 32 Cal.3d 128, 142-143 [ 185 Cal.Rptr. 232 , 649 P.2d 874 ].) Although this standard is deferential, a court abuses its discretion “ ‘where no reasonable basis for the action is shown. [Citation.]’ ” (Westside Community for Independent Living, Inc. v. Obledo (1983) 33 Cal.3d 348, 355 [ 188 Cal.Rptr. 873 , 657 P.2d 365 ].) Determination of the proper amount of the award under section 1021.5 is within the trial court’s discretion, but the ultimate award “must still bear some reasonable relationship to the lodestar figure and to the purpose of the private attorney general

2014(Baggett v. Gates (1982) 32 Cal.3d 128, 142-143 [ 185 Cal.Rptr. 232 , 649 P.2d 874 ].) Although this standard is deferential, a court abuses its discretion “ ‘where no reasonable basis for the action is shown. [Citation.]’ ” (Westside Community for Independent Living, Inc. v. Obledo (1983) 33 Cal.3d 348, 355 [ 188 Cal.Rptr. 873 , 657 P.2d 365 ].) Determination of the proper amount of the award under section 1021.5 is within the trial court’s discretion, but the ultimate award “must still bear some reasonable relationship to the lodestar figure and to the purpose of the private attorney general

2024The statute codifies the private attorney general doctrine and “the courts’ ‘traditional equitable discretion’ concerning attorney fees …, and within the statutory parameters courts retain considerable discretion.” (Vasquez v. State of California (2008) 45 Cal.4th 243, 251 .) “In deciding whether to award fees, the court ‘must realistically assess the litigation and determine, from a practical perspective, whether or not the action served to vindicate an important right so as to justify an attorney fee award under a private attorney general theory.’” (Ibid.) This appeal challenges a trial cour

2016Legal Principles and Standard of Review Code of Civil Procedure section 1021.5 provides in part: "Upon motion, a court may award attorneys' fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement, or of enforcement by one public entity against another public entity, are such as to make the

2019The City contends Boatworks is not entitled to these fees. " 'Under the private burden prong of section 1021.5, fees are recoverable " 'when the cost of the claimant's legal victory transcends his personal interest, that is, when the necessity for pursuing the lawsuit placed a burden on the plaintiff "out of proportion to his individual stake in the matter." ' " [Citation.] "If the enforcement of the public interest is merely 'coincidental to the attainment of ... personal goals' [citation] or is 'self-serving,' [citation], then this requirement is not met." [Citation.] "Stated otherwise, 'The

2019The City contends Boatworks is not entitled to these fees. " 'Under the private burden prong of section 1021.5, fees are recoverable " 'when the cost of the claimant's legal victory transcends his personal interest, that is, when the necessity for pursuing the lawsuit placed a burden on the plaintiff "out of proportion to his individual stake in the matter." ' " [Citation.] "If the enforcement of the public interest is merely 'coincidental to the attainment of ... personal goals' [citation] or is 'self-serving,' [citation], then this requirement is not met." [Citation.] "Stated otherwise, 'The

2021DISCUSSION Section 1021.5 authorizes a court to “award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement, or of enforcement by one public entity against another public entity, are such as to make the award appropriate, and (c) such fees should not in the interest of justic

2018DISCUSSION A. Statutory Framework and Standards of Review " Section 1021.5 codifies California's version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases." ( Robinson v. City of Chowchilla (2011) 202 Cal.App.4th 382 , 390, 134 Cal.Rptr.3d 696 ( Robinson ).) In particular, "[t]he doctrine rests upon the recognition that privately initiated lawsui

2010The guiding principles for applications for private attorney fees under section 1021.5 (1) Codified in section 1021.5, the private attorney general doctrine, under which attorney fees may be awarded to successful litigants, "rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of the fundamental public policies embodied in constitutional or statutory provisions, and that, without some mechanism authorizing the award of attorney fees, private actions to enforce such important public policies will as a practical matter frequently be infeasible. [Ci

2010The guiding principles for applications for private attorney fees under section 1021.5 (1) Codified in section 1021.5, the private attorney general doctrine, under which attorney fees may be awarded to successful litigants, "rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of the fundamental public policies embodied in constitutional or statutory provisions, and that, without some mechanism authorizing the award of attorney fees, private actions to enforce such important public policies will as a practical matter frequently be infeasible. [Ci

2016Section 1021.5 was enacted as " 'a codification of the "private attorney general" attorney fee doctrine that had been developed in numerous prior judicial decisions.... [T]he fundamental objective of the private attorney general doctrine of attorney fees is " 'to encourage suits effectuating a strong [public] policy by awarding substantial attorney's fees ... to those who successfully bring such suits and thereby bring about benefits to a broad class of citizens.' " [Citation.] The doctrine rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of

2016Section 1021.5 was enacted as " 'a codification of the "private attorney general" attorney fee doctrine that had been developed in numerous prior judicial decisions.... [T]he fundamental objective of the private attorney general doctrine of attorney fees is " 'to encourage suits effectuating a strong [public] policy by awarding substantial attorney's fees ... to those who successfully bring such suits and thereby bring about benefits to a broad class of citizens.' " [Citation.] The doctrine rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of

2022Section 1021.5 Attorney Fees: Legal Standards and Standard of Review “ ‘Section 1021.5 codifies the private attorney general doctrine the Supreme Court adopted in Serrano v. Priest (1977) 20 Cal.3d 25 . . . . [Citation.] “ ‘ “The doctrine rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of the fundamental public policies embodied in constitutional or statutory provisions, and that, without some mechanism authorizing the award of attorney fees, private actions to enforce such important public policies will as a practical matter frequently be i

2021Discussion Code of Civil Procedure section 1021.5 (section 1021.5) authorizes a court to “award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement . . . are such as to make the award appropriate, and (c) such fees should not in the interest of justice be paid out of the rec

2021(Flannery v. California Highway Patrol (1998) 61 Cal.App.4th 629, 634 (Flannery).) “Underlying the private attorney general doctrine is the recognition that privately initiated lawsuits often are 36 essential to effectuate fundamental public policies embodied in constitutional or statutory provisions, and that without some mechanism authorizing a fee award, such private actions often will as a practical matter be infeasible.

2016Section 1021.5 was enacted as " 'a codification of the "private attorney general" attorney fee doctrine that had been developed in numerous prior judicial decisions.... [T]he fundamental objective of the private attorney general doctrine of attorney fees is " 'to encourage suits effectuating a strong [public] policy by awarding substantial attorney's fees ... to those who successfully bring such suits and thereby bring about benefits to a broad class of citizens.' " [Citation.] The doctrine rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of

2014As this court explained in Best, "the private attorney general doctrine embodied in California's section 1021.5 '. . . rests upon the recognition that privately initiated lawsuits are often essential to the effectuation of the fundamental public policies embodied in constitutional or statutory provisions, and that, without some mechanism authorizing the award of attorney fees, private actions to enforce such important public policies will as a practical matter frequently be infeasible.' [Citation.] Whether the private enforcement of public policies is achieved through an administrative and/or

2010Appellant relies on, e.g., Best v. California Apprenticeship Council (1987) 193 Cal.App.3d 1448 [ 240 Cal.Rptr. 1 ], and its citation of Serrano III, supra, 20 Cal.3d 25 , to the effect that California courts “have the equitable power to award attorney’s fees under the private attorney general doctrine, at least when constitutional rights are vindicated, even absent statutory authorization,.” (Be st, supra, at p. 1462, fn. 12, italics added.) Absent more recent guidance from the Supreme Court, we decline to explore the extent to which the trial court might retain noncodified, inherent equitabl

2019Statutory Framework and Standards of Review Recently, in City of Oakland v. Oakland Police & Fire Retirement System (2018) 29 Cal.App.5th 688 , 240 Cal.Rptr.3d 571 ( Oakland PFRS ), we summarized the underlying purpose of section 1021.5 as follows: " ' Section 1021.5 codifies California's version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.

2019Statutory Framework and Standards of Review Recently, in City of Oakland v. Oakland Police & Fire Retirement System (2018) 29 Cal.App.5th 688 , 240 Cal.Rptr.3d 571 ( Oakland PFRS ), we summarized the underlying purpose of section 1021.5 as follows: " ' Section 1021.5 codifies California's version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.

2017II DISCUSSION A Section 1021.5 states in part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement... are such as to make the award appropriate, and (c) such fees should not in the interest of justice be paid out of the recovery, if any.” “Sec

2017II DISCUSSION A Section 1021.5 states in part: “Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest if: (a) a significant benefit, whether pecuniary or nonpecuniary, has been conferred on the general public or a large class of persons, (b) the necessity and financial burden of private enforcement... are such as to make the award appropriate, and (c) such fees should not in the interest of justice be paid out of the recovery, if any.” “Sec

2010Statutory Elements (1) Section 1021.5 codifies the private attorney general doctrine, which provides an exception to the "`"American rule"'" that each party bears its own attorney fees. ( Olson v. Automobile Club of Southern California (2008) 42 Cal.4th 1142, 1147 [ 74 Cal.Rptr.3d 81 , 179 P.3d 882 ].) The fundamental objective of the private attorney general doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases. ( Graham v. DaimlerChrysler Corp. (2004) 34 Cal.4th 553, 565 [ 21 Cal.Rptr.3d 331 , 101 P.3d

2010Statutory Elements (1) Section 1021.5 codifies the private attorney general doctrine, which provides an exception to the "`"American rule"'" that each party bears its own attorney fees. ( Olson v. Automobile Club of Southern California (2008) 42 Cal.4th 1142, 1147 [ 74 Cal.Rptr.3d 81 , 179 P.3d 882 ].) The fundamental objective of the private attorney general doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases. ( Graham v. DaimlerChrysler Corp. (2004) 34 Cal.4th 553, 565 [ 21 Cal.Rptr.3d 331 , 101 P.3d

2019Statutory Framework and Standards of Review Recently, in City of Oakland v. Oakland Police & Fire Retirement System (2018) 29 Cal.App.5th 688 , 240 Cal.Rptr.3d 571 ( Oakland PFRS ), we summarized the underlying purpose of section 1021.5 as follows: " ' Section 1021.5 codifies California's version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.

2019Statutory Framework and Standards of Review Recently, in City of Oakland v. Oakland Police & Fire Retirement System (2018) 29 Cal.App.5th 688 , 240 Cal.Rptr.3d 571 ( Oakland PFRS ), we summarized the underlying purpose of section 1021.5 as follows: " ' Section 1021.5 codifies California's version of the private attorney general doctrine, which is an exception to the usual rule that each party bears its own attorney fees. [Citation.] The purpose of the doctrine is to encourage suits enforcing important public policies by providing substantial attorney fees to successful litigants in such cases.