The trial court did not abuse its discretion in assessing against a trust beneficiary’s share and against the beneficiary personally the attorney fees incurred by the trustee in defending against the beneficiary’s objections to the trustee’s third accounting.  Under Prob. Code 17211(a), the court may award such fees if it finds that the contest was without reasonable cause and in bad faith.  The trial court’s findings on bad faith and lack of reasonable cause were supported by substantial evidence.  The objection was defeated on all grounds, many of which were petty or decided on approval of previous accounting.  Bad faith was evident in the objection’s vitriolic personal attacks of the trustee and other beneficiaries.

California Court of Appeal, Fourth Appellate District, Division 1 (McConnell, P.J.); August 6, 2018 (published August 15, 2018); 2018 Cal. App. LEXIS 724