Oden v. Shane Smith Enterprises, Inc., No. 21-1070 (8th Cir. 2022)
Annotate this CaseThe Eighth Circuit affirmed the district court's reduction of SLF's request for an award of attorneys' fees. The court also affirmed the denial of SLF's motion to recuse, concluding that the unsupported and self-serving affidavit submitted by an SLF employee was not enough to leave the court with a definite and firm conviction that a mistake occurred. The court stated that recognizing SLF's practices for what they are—overbilling— does not call a judge's ability to render a fair judgment into question. The court rejected SLF's argument that the district court abused its discretion by excluding some of SLF's work from its fee calculation and imposing a 20% reduction on SLF's requested fees. Rather, SLF engaged in negotiating tactics that unreasonably extended the litigation, wasting the district court's time and resources. Therefore, the district court was entitled to reduce the lodestar calculation by considering appropriate factors, including unprofessional conduct.
Court Description: [Kobes, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Civil case - Fair Labor Standards Act. The district court did not abuse its discretion in reducing plaintiffs' lawyers' request for an award of attorneys' fees; the district court did not err in denying the law firm's motion to recuse.
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