Post-Judgment Fees Don't Require a Number in the Judgment

Guo v. Moorpark Recovery Svc., LLC, No. A159195 (D1d5 Feb. 8, 2021)  

When a judgment includes an award of attorneys’ fees under a contractual fee provision, Code of Civil Procedure § 685.040 authorizes the creditor to also recover fees incurred in enforcing the judgment. Here, the creditor got a default judgment, which included a statement that it was entitled to a fee award. But the creditor never filed a cost bill to actually recover those fees so no ultimate judgment ever specified an amount. The Court of Appeal here holds that doesn’t matter. So long as the underlying judgment stated that the creditor was entitled to fees, that was adequate for the creditor to obtain fees for collection under § 685.040.

Reversed.