October 2025 Family Law Update

General MCLE Credits: 0.50
Family Law LSCLE Credits: 0.50
24 minutes

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Marriage of Nelson. Family Code §4360, which requires a supporting spouse to purchase an annuity, maintain life insurance, or fund a trust is not conflict with §4337, which terminates spousal support upon the death of either party because the Court only orders a supporting spouse to purchase / maintain / fund during his / her lifetime. To make such an order, the “court must find that an order under the statute is just and reasonable in view of the circumstances of the parties.”

Hart v. Hart. Courts do not have discretion to renew a restraining order for less than five years. Renewing a restraining order for 9 months was reversible error.

Marriage of Elena Kouvabina and Jacob Veltman. Court deemed a self-represented litigant a vexatious litigant after Kouvabina commenced, prosecuted, or maintained nine appeals and writs over 5 years while self-represented that were finally determined adversely to her. It was of no consequence that she was (at times) the responding party at the trial court level; that issues were bifurcated; that the litigation was in the form of appeals / writs; that this was a family law case; or that she was only self-represented because the court denied her fee request.

P. v. Alvarez. Attorney referred to the State Bar and sanctioned $1,500 for using AI hallucinations in a brief.

Kim v. New Life Oasis Church. Issue preclusion precluded attorney from filing a cause of action related to an issue decided in a case in which he was the attorney of record, even though he was not a party to the case, because he had a proprietary or financial interest in the decision rendered in the other case and through his role as an attorney of record was in privity with a party in the first litigation.

In re Claudia R. Department should make reasonable inquiries (or at least ask for the contact information) to extended family member who are identified by the parents

In re R.L. Generally, jurisdictional findings under WIC 300(a) may not be based on a single episode of endangering conduct in the absence of evidence that such conduct is likely to reoccur.