SLAPP Fee Award Held Not Appealable If SLAPP Order Itself Is Not Appealed

Timothy Kowal, Esq.
December 22, 2022

CEB has published my article, “SLAPP Fee Award Held Not Appealable If SLAPP Order Itself Is Not Appealed.”

The article is about a recent appellate opinion, Ibbetson v. Grant (D4d3 Nov. 30, 2022) No. G060473 (nonpub. opn.), that holds that an order on an anti-SLAPP fee motion is not appealable. But there are conflicting cases on this point, and the Ibbetson opinion, while trying to reconcile to disparate cases, potential added to the confusion.

The important takeways:

  1. Don’t count on anti-SLAPP fee awards being independently appealable.
  2. But don’t count out the possibility they might be appealable as collateral orders.

Here is a link to the PDF: Kowal_SLAPPFeeAward.pdf

Here is a link to the original blog post.

Tim Kowal is an appellate specialist certified by the California State Bar Board of Legal Specialization. Tim helps trial attorneys and clients win their cases and avoid error on appeal. He co-hosts the Cal. Appellate Law Podcast at, and publishes a newsletter of appellate tips for trial attorneys at Contact Tim at or (714) 641-1232.

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