Padgett, et al v. Loventhal, et al, No. 10-16533 (9th Cir. 2013)
Annotate this CaseThis case stemmed from plaintiffs' complaint asserting state and federal causes of action against eight defendants. At issue on appeal was the district court's award of attorney's fees and costs to Plaintiff Joseph Padgett. The court vacated the district court's award of costs and attorney's fees because the district court provided no explanation of how it calculated them. The court remanded to the district court for an explanation of how it used the lodestar method to reduce Padgett's fees and how it calculated Padgett's reduced costs. For the same reason, the district court erred in failing to explain why it denied costs to the prevailing defendants. While the district court had discretion to depart from Federal Rule of Civil Procedure 54(d) in appropriate cases, the court could not review its unexplained order for abuse of discretion. Accordingly, the court vacated and remanded.
Court Description: Civil Rights / Attorneys’ Fees. The panel vacated the district court’s award of costs and attorneys’ fees in a 42 U.S.C. § 1983 action, and remanded to the district court for an explanation of how it used the lodestar method to reduce plaintiff’s fees and how it calculated plaintiff’s reduced costs. The panel held that in reducing plaintiff’s fee request for $3.2 million in fees and $900,000 in costs, the district court did not explain how it determined that $500,000 in fees and $100,000 in costs was appropriate or why it denied costs to the prevailing defendants. As a result, the panel was unable to review the district court’s reasoning. The panel stated that the mandate that district courts show their work in calculating fees was all the more important in cases such as this one where there were many overlapping claims and a very mixed result. Therefore, the panel vacated and remanded for a more complete explanation.
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