Travis v. Brand, 523 P.3d 380

Redondo Beach voters approved Measure G (2010) enabling a large waterfront development; opponents later qualified Measure C (2017) to restrict zoning for that project.
Plaintiffs Arnette Travis and Chris Voisey sued several Measure C supporters under the Political Reform Act, alleging undisclosed PAC identity and candidate control of Rescue Our Waterfront.
After a five-day bench trial the trial court ruled for defendants, found the suit frivolous/unreasonable, and awarded defendants $896,896.60 in attorneys’ fees under Gov. Code § 91003(a).
The Court of Appeal affirmed, holding § 91003(a) permits awarding fees to a prevailing plaintiff or defendant on the same basis (i.e., no special limit on defendants).
The Supreme Court granted review to resolve whether an asymmetrical standard limits fee awards to prevailing defendants under the Political Reform Act.
The Supreme Court reversed and remanded, holding the Christiansburg/Williams asymmetrical standard governs fee awards to prevailing defendants and the Court of Appeal failed to apply that standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gov. Code § 91003(a) requires a special standard for awarding fees to prevailing defendants in Political Reform Act suits	Travis: Prevailing defendants may recover fees only if the plaintiff’s suit was frivolous, unreasonable, or objectively without foundation	Defendants: § 91003(a) is neutral; prevailing plaintiffs and defendants should be treated the same for fee awards	Held: Apply an asymmetrical standard—prevailing defendants may get fees only if the plaintiff’s action was objectively without foundation when brought or continued after it clearly became so (Christiansburg/Williams standard)
Whether the Court of Appeal properly affirmed the fee award without applying the asymmetrical standard or considering CCP § 1021.5	Travis: Court of Appeal should have applied the asymmetrical standard and considered other statutory grounds before affirming fees	Defendants: Court of Appeal acted within its discretion in affirming fees to prevailing defendants	Held: Court of Appeal erred by not applying the required standard; case remanded for the Court of Appeal to consider whether the standard is met or whether fees can be affirmed under CCP § 1021.5

Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (U.S. 1978) (establishes that prevailing defendants in civil‑rights suits may recover fees only if plaintiff’s claim was frivolous, unreasonable, or without foundation)
Fogerty v. Fantasy, Inc., 510 U.S. 517 (U.S. 1994) (applies statutory purpose inquiry to decide whether prevailing plaintiffs and defendants should be treated alike for fee awards in copyright cases)
Williams v. Chino Valley Indep. Fire Dist., 61 Cal.4th 97 (Cal. 2015) (California adopts Christiansburg‑style asymmetrical standard for FEHA fee awards to prevailing defendants)
People v. Roger Hedgecock for Mayor Committee, 183 Cal.App.3d 810 (Cal. Ct. App. 1986) (applies Christiansburg rationale to Political Reform Act fee requests to protect private enforcement)
Community Cause v. Boatwright, 195 Cal.App.3d 562 (Cal. Ct. App. 1987) (affirmed that prevailing defendants under the Political Reform Act should recover fees only if plaintiff’s claim was frivolous or groundless)
Pollock v. Tri‑Modal Distribution Services, Inc., 11 Cal.5th 918 (Cal. 2021) (confirms use of statutory purpose and legislative history to interpret fee statutes and apply asymmetrical standards)