Marriage of Golka
In April 2011, judgment was entered dissolving the marriage of Daniel Golka and Doreen Golka.[1] Pursuant to Daniel and Doreen’s stipulation, the judgment resolved all issues between them, including issues related to support, custody, and visitation, except for one—whether the trial court should award to either party attorney fees, costs, or sanctions. Following trial on the issue of attorney fees, costs, and sanctions, the court entered a judgment ordering Daniel to pay sanctions “related to his conduct,†in the total amount of $45,000 (the judgment on the reserved issue). The judgment on the reserved issue further directed that the sanctions be paid directly from the escrow account containing Daniel’s share of the proceeds from the sale of the family residence. The trial court denied Daniel’s motion for a new trial.
We affirm the judgment on the reserved issue. For the reasons we will explain, we reject each of Daniel’s contentions of error and hold that (1) sufficient evidence supported the sanctions award; (2) the sanctions award did not impose an unreasonable financial burden on Daniel; (3) the trial court did not deprive Daniel of a fair trial by denying him the rights to present evidence, cross‑examine witnesses, and testify on his own behalf; and (4) the trial judge did not demonstrate “bias and prejudice†against self‑employed businessmen in general or against Daniel specifically.
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