american rule
 

* 1.California follows what is commonly referred to as the American rule, which provides that each party to a lawsuit must ordinarily pay his own attorney fees. (Gray v. Don Miller &amp Associates, Inc. (1984) 35 Cal.3d 498, 504 United Services Auto. Assn. v. Dalrymple (1991) 232 Cal.App.3d 182, 87.) The Legislature codified the American rule in 1872 when it enacted Code of Civil Procedure section 1021, which states in pertinent part that Except as attorney's fees are specifically provided for by statute, the measure and mode of compensation of attorneys and counselors at law is left to the agreement, express or implied, of the parties . . . (See, e.g., Bruno v. Bell (1979) 91 Cal.App.3d 776, 781