Members may bring an action in small claims court to enforce their right to inspect and copy the association's records. Making a request for ADR is not required before going into small claims court. If the court finds that the association unreasonably withheld records, the court may assess a penalty of up to $500 for the denial of each separate written request and order the production of records. Civil Code §1365.2(f).

Frivolous Court Actions. If owners bring an action in small claims that the court finds is frivolous, unreasonable, or without foundation, the court can award costs to the association. Civil Code §1365.2(f).