When there are more than one defendant in a civil case, how is the court apportioned attorney general's fees between the City and County?

Apportionment may certainly be appropriate where there is more than one defendant. For example in Sundance v. Municipal Court (1987) 192 Cal.App.3d 268, 237 Cal.Rptr. 269, a successful challenge to the prosecution of public inebriates supported a fee award made equally against the City and County of Los Angeles. (Id. at p. 272, 237 Cal.Rptr. 269.) On appeal the County challenged this 50/50 allocation arguing it had committed fewer of the abuses corrected by the lawsuit and therefore it should not pay as much as its more culpable co-defendant, the City. (Ibid.) The appellate court upheld the apportionment, noting that the County had taken "an active part in opposing the litigation and thus in generating the expenses that are compensated by the award of attorneys' fees." (Ibid.)

It is certainly reasonable, given the facts of a specific case, for a court to

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