Aida Herrera-Jerez v. Hyundai Motor America

CourtNew Jersey Superior Court Appellate Division
DecidedOctober 22, 2024
DocketA-3290-22
StatusUnpublished

This text of Aida Herrera-Jerez v. Hyundai Motor America (Aida Herrera-Jerez v. Hyundai Motor America) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aida Herrera-Jerez v. Hyundai Motor America, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3290-22

AIDA HERRERA-JEREZ,

Plaintiff-Appellant,

v.

HYUNDAI MOTOR AMERICA, a/k/a HYUNDAI USA,

Defendant-Respondent. _____________________________

Argued October 10, 2024 – Decided October 22, 2024

Before Judges Mawla, Natali, and Vinci.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-8139-20.

David C. Ricci argued the cause for appellant (Law Offices of David C. Ricci, LLC, attorneys; David C. Ricci, on the briefs).

Mark W. Skanes (RoseWaldorf PLLC) argued the cause for respondent.

PER CURIAM After plaintiff Aida Herrera-Jerez settled her Magnusson-Moss Warranty

Act1 (MMWA) claim against defendant Hyundai Motor America, plaintiff

moved for an award of attorney's fees and costs pursuant to the fee-shifting

provision of the MMWA, as expressly contemplated in the parties' written

settlement agreement. Plaintiff requested oral argument if the motion was

opposed, which it was.

On May 19, 2023, without hearing oral argument, the court entered an

order, supported by a written opinion, reducing plaintiff's fee award from

$35,332.50 to $2,449. Plaintiff appeals from that order. Because the court did

not hear oral argument and did not make specific findings to explain its drastic

reduction of the fee award, we are constrained to vacate the order and remand

for reconsideration of plaintiff's motion.

On November 28, 2020, plaintiff filed a complaint against defendant

asserting a single cause of action based on the MMWA, relating to her 2017

Hyundai Sante Fe. Plaintiff alleged the vehicle had a long history of engine

defects that defendant failed to timely repair in violation of its written

warranties. The parties were unable to reach an early settlement and litigated

the action for over two years.

1 15 U.S.C. §§ 2301-2312. A-3290-22 2 The litigation progressed in typical fashion. Plaintiff served discovery

demands on defendant. Defendant moved to quash subpoenas plaintiff served

on dealerships that serviced the vehicle resulting in briefing and oral argument

on that motion. Defendant served written discovery on plaintiff, including

interrogatories, requests for admissions, and document requests, to which

counsel was obligated to prepare responses. Defendant retained an expert who

inspected the vehicle and prepared an expert report. Defendant also deposed

plaintiff, which required counsel to expend time to prepare plaintiff for and

attend the deposition. After discovery was completed, the parties participated

in an unsuccessful non-binding arbitration.

On August 31, 2022, defendant offered to settle the action for $7,500 plus

"reasonable attorney's fees and costs to be decided by the [c]ourt on motion."

On December 22, 2022, the parties executed a written settlement agreement and

release. The agreement provides:

[Defendant] agrees to have the attorney's fees and costs of [plaintiff's] attorneys, Law Office of David C. Ricci, LLC, to have been reasonably incurred by [plaintiff], to be determined by the [c]ourt upon a properly noticed motion. Notwithstanding this provision, [defendant] reserves all rights to challenge the reasonableness of the attorney's fees and costs requested by [plaintiff]. However, [defendant] agrees that it will not challenge the right of . . . [plaintiff] to receive attorney's fees and costs as determined by the [c]ourt.

A-3290-22 3 On March 15, 2023, plaintiff filed a motion for judgment awarding

attorney's fees and costs. Plaintiff requested oral argument if the motion was

opposed. Plaintiff sought costs and expenses of $552.20, and attorney's fees of

$35,884.70. The motion was supported by the certification of plaintiff's counsel

in which he certified he accepted the case on a contingent basis and, as set forth

in his attached billing records, devoted 67.3 hours to the matter. Counsel also

certified the fee application was based on his then-current hourly rate of $525,

which he contended was reasonable and consistent with hourly rates approved

in other similar litigation.

Defendant opposed the motion arguing the amount of time counsel

devoted to the case was unreasonable. It argued counsel's time was "improperly

block billed" and counsel took too long to perform certain tasks, such as his

preliminary pre-suit investigation, drafting the complaint, responding to its

motion to quash, and preparing plaintiff's arbitration statement. Defendant also

contended counsel's hourly rate was unreasonable because defense counsel's

hourly rate was less than $250 and plaintiff's counsel had only recently raised

his hourly rate from $475 to $525. Defendant argued much of the work counsel

performed could have been completed by paraprofessionals at a lower rate.

A-3290-22 4 Finally, defendant argued the fee award sought was unreasonable in relation to

the result obtained.

The court did not hear oral argument. On May 19, 2023, the court entered

an order entering judgment for award of attorney's fees and costs supported by

a written opinion. After summarizing the arguments advanced by the parties,

the court offered the following "statement of reasons":

Court finds reasonable rate in Essex County is $395[] per hour.

Drafting [c]omplaint 2.7

Defend [d]eposition of [c]lient 2.3

Attend [a]rbitration [h]earing 1.2

Expenses: $552.20

Plaintiff's [c]ounsel has [eighteen] years of experience and has been involved in over 1,000 matters so he is not entitled to be reimbursed for research. The court is awarding the reasonable fees based on the result obtained. Plaintiff is awarded $2,449[] in fees and $552.20 in costs.

On appeal, plaintiff argues the court erred by issuing an unexplained and

inadequately low fee award and not hearing oral argument. We are persuaded

that the court's statement of reasons lacks specific and adequate findings

regarding the reasonableness of the services performed and does not explain the

A-3290-22 5 basis for the court's determination of the reasonable hourly rate. We are also

convinced the court misapplied its discretion by not hearing oral argument.

"[F]ee determinations by trial courts will be disturbed only on the rarest

occasions, and then only because of a clear abuse of discretion." Rendine v.

Pantzer, 141 N.J. 292, 317 (1995). Although the "abuse of discretion" standard

defies precise definition, it arises when a decision is "made without a rational

explanation, inexplicably departed from established policies, or rested on an

impermissible basis." Flagg v. Essex Cnty. Prosecutor, 171 N.J. 561, 571 (2002)

(quoting Achacoso-Sanchez v. Immigr. & Naturalization Serv., 779 F.2d 1260,

1265 (7th Cir. 1985)).

"The starting point in awarding attorney's fees is the determination of the

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Bluebook (online)
Aida Herrera-Jerez v. Hyundai Motor America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aida-herrera-jerez-v-hyundai-motor-america-njsuperctappdiv-2024.