Unless he moves to intervene, an unnamed class member lacks standing to appeal an attorney fee award to class counsel following entry of a class action judgment; mere objection to class counsel’s motion for a fee award does not suffice. Finding itself bound to follow Eggert v. Pac. States S. & L. Co. (1942) 20 Cal.2d 199, this decision holds that an unnamed class member does not, simply by objecting to an attorney fee award to class counsel following entry of judgment after trial of the class action, gain standing to appeal from the fee award. Instead, to appeal, the class member must move to intervene after the fee award is entered and then move to vacate the award. The class member can then appeal from denial of either the motion to intervene or the motion to vacate, or both.
California Court of Appeal, Fourth District, Division 1 (McDonald, J.); March 14, 2016; 2016 WL 945156