The California Court of Appeal recently upheld a ruling that awarded attorney fees to the Los Rios Community College District and its officials in a case brought by plaintiff Tuesday Seales-Perkins. The court's decision, filed on October 27, 2026, comes after Seales-Perkins appealed the trial court's order regarding attorney fees and monetary sanctions. This ruling is significant as it addresses the complexities of attorney fee awards in cases involving anti-SLAPP motions, which are designed to prevent strategic lawsuits against public participation.

Seales-Perkins, who represented herself in this case, challenged the trial court's decision on two main grounds. First, she argued that the court failed to specify the hours that the defendants' counsel spent on successful claims when awarding attorney fees. Second, she contended that the court did not adequately protect her public benefits income when imposing monetary sanctions related to discovery disputes. The court ultimately affirmed the attorney fees order and dismissed her appeal regarding the monetary sanctions.

The parties involved in this case are Tuesday Seales-Perkins, the plaintiff and appellant, and the Los Rios Community College District, along with its officials Albert Garcia, Andre Coleman, Toni Newman, and Linda Delgadillo, who are the defendants and respondents. The dispute began when Seales-Perkins filed a lawsuit against the college district, which led to the defendants filing an anti-SLAPP motion to strike portions of her complaint. This motion was partially granted, prompting the trial court to award attorney fees to the defendants.

The case reached the California Court of Appeal after Seales-Perkins filed multiple notices of appeal regarding various orders from the trial court. The attorney fees order was issued after the trial court determined that the defendants had been largely successful in their anti-SLAPP motion. The court noted that the allegations made by Seales-Perkins were intertwined, making it difficult to separate the work performed by the defendants' counsel on successful claims from that on unsuccessful ones.

In its ruling, the court referenced the legal standard set forth in the case of Mann v. Quality Old Time Service, Inc., which states that a defendant who partially prevails on an anti-SLAPP motion may recover attorney fees that are reasonably allocable to achieving that victory. The trial court found that it was not possible to allocate specific hours to particular claims due to the overlapping nature of the work involved. However, it did reduce the compensable hours from 82.6 to 70, acknowledging that the motion was not entirely successful.

The court stated, "The trial court is best positioned to determine whether to award fees and costs … and to determine … the appropriate allocations and the amounts reasonably awardable." This indicates that the appellate court upheld the trial court's discretion in making its determination regarding attorney fees.

Regarding the monetary sanctions, the court dismissed Seales-Perkins' appeal, stating that her motion for relief from the sanctions effectively requested the trial court to reconsider its previous ruling. The court noted that an order denying a motion for reconsideration is not appealable, further solidifying the trial court's authority in such matters.

This ruling has implications for future cases involving anti-SLAPP motions and attorney fees, as it reinforces the importance of the trial court's discretion in determining reasonable fees in complex litigation. It also highlights the challenges that self-represented litigants may face in navigating the legal system, particularly when dealing with procedural issues and the intricacies of attorney fee awards.

Moving forward, this case may serve as a reference point for similar disputes involving attorney fees in anti-SLAPP cases. While the court's decision is final in this instance, it is important to note that Seales-Perkins could potentially seek further legal recourse, although the court did not provide details on any related cases pending or the possibility of an appeal to a higher court.