Roberts v. City and County of Honolulu, No. 16-16179 (9th Cir. 2019)
Annotate this CaseThe Ninth Circuit vacated the district court's award of attorney's fees after the settlement of a civil rights action. The panel held that the district court abused its discretion by failing to apply the correct legal standard for awarding legal fees and thus remanded for the application of the correct legal standard. In this case, the district court's wholesale rejection of the relevant attorney declarations, and the district court's singular reliance on the hourly rates previously awarded to counsel in unrelated cases departed from the correct legal standard and constituted legal error. The panel also remanded for the district court to make a specific finding regarding when the settlement agreement became final.
Court Description: Civil Rights/Attorney’s Fees. The panel vacated the district court’s award of attorney’s fees, following the settlement of a civil rights action brought pursuant to 42 U.S.C. § 1983, and remanded. The panel held that plaintiff received substantially all of his requested relief in the settlement agreement. As a result, as the prevailing party, he was entitled to reasonable attorney’s fees. The panel held that the district court failed to apply the correct legal standard in determining the prevailing attorney hourly rate. Specifically, the panel held that the district court’s wholesale rejection of the relevant attorney declarations submitted by plaintiffs and the court’s singular reliance on the hourly rates previously awarded to plaintiffs in unrelated cases departed from the correct legal standard and constituted legal error, resulting in an abuse of discretion. The panel remanded for the district court to determine a reasonable hourly rate, adduced by examining rates for comparable work performed by attorneys in the relevant community with similar skill, experience, and reputation. The panel further remanded for the district court to make a specific finding regarding when the settlement agreement was sufficiently final for purposes of determining whether plaintiffs were entitled to compensation for unfiled motions. ROBERTS V. CITY AND COUNTY OF HONOLULU 3
The court issued a subsequent related opinion or order on December 27, 2019.
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