BRADLEY v. United States

CourtUnited States Court of Federal Claims
DecidedApril 20, 2026
Docket19-400
StatusPublished

This text of BRADLEY v. United States (BRADLEY v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BRADLEY v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims No. 19-400 Filed: April 20, 2026

ELIZABETH G. BRADLEY, et al.,

Plaintiffs,

v.

THE UNITED STATES,

Defendant.

ORDER

“[T]o leave a place is one thing, but to leave it twice is quite another.” Oscar Wilde, The Picture of Dorian Gray 48 (2003 ed., Penguin Classics). So too here, as the Court warily returns to a fee dispute obviously better suited for resolution by agreement than by judicial intervention. Invoking the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (“URA”), Plaintiffs previously sought an award of attorneys’ fees and litigation expenses reflecting work required to bring the most recent group of settled plaintiffs to resolution. 1 (Pls.’ Second Fee Mot., ECF No. 190); 42 U.S.C. § 4654(c). The Court granted that request in part and directed Plaintiffs to submit a revised fee petition omitting all fees and costs associated with the eight Group 1 Plaintiffs and including documentation supporting fees incurred after the filing of the URA petition. (Op. on URA Fees, ECF No. 199). Plaintiffs timely filed their amended submission, (Pls.’ Am. Fee Mot., ECF No. 200), and the United States subsequently objected, (Def.’s Resp., ECF No. 201). For the reasons set forth below, the Court GRANTS Plaintiffs’ request in part and awards a total of $415,326.51.

The Court’s preceding fee decision thoroughly recounts the factual and procedural history of this litigation, as well as the applicable legal framework. (Op. on URA Fees at 2–7 (Background), 7–18 (Analysis)). Because that Opinion sufficiently addressed the foundational background and relevant case law, this Opinion will not restate those elements and incorporates them herein. While the Court provides a cursory summary of the relevant facts for context, its analysis remains focused exclusively on the merits of Plaintiffs’ amended fee request and the United States’ objections.

1 Plaintiffs previously sought and obtained a URA fee award in 2023, making the principal request their Second Fee Motion. (ECF No. 113); Bradley v. United States, 164 Fed. Cl. 236, 244 (2023). Left unresolved, URA fee petitions ordinarily proceed in a predictable sequence: once the merits are resolved, plaintiffs submit their request, the United States responds, and the Court addresses whatever narrow disputes remain. This case has unfolded quite differently. Plaintiffs now seek $379,856.03 in attorneys’ fees and $50,461.03 in costs and expenses, totaling $430,317.06. (Pls.’ Am. Fee Mot. at 4). They represent that this figure reflects the Court-ordered omission of certain costs and fees and includes supplemental fees for work performed after the filing of their Second Fee Motion. (Id.). That earlier motion, filed on June 23, 2025, sought $471,268.79 and reflected expenses and costs incurred from the inception of this case to May 20, 2025. (Pls.’ Second Fee Mot. at 24). As alluded to, Plaintiffs’ filing did not proceed in the ordinary course. Once Plaintiffs filed their Second Fee Motion, the United States immediately moved to strike that submission, (ECF No. 191), prompting full briefing, (ECF Nos. 192, 193). Following a conference to discuss the Motion to Strike, the Court denied the United States’ request and deemed the Second Fee Motion filed as of that date. (Dkt. Entry 7/14/2025).

Although the Court set a schedule for the United States’ response, the United States submitted its “Statement Respecting Plaintiffs’ Second Motion for Attorneys’ Fees and Expenses.” (ECF No. 197). In lieu of a substantive response, the United States doubled down on its position that this Court lacked jurisdiction to adjudicate the fee petition, given the pending appeal of the liability judgment. (Id. at 6–8 (citing Bradley v. United States, CAFC No. 25-1811 (docketed May 28, 2025))). Plaintiffs replied, informally requesting an additional $37,062.50 in fees and costs incurred between May 20 and August 25, 2025. (ECF No. 198 at 12). On December 17, 2025, the Court granted the Second Fee Motion in part and denied it in part, directing Plaintiffs to submit an amended request omitting fees related to the “Group 1 Plaintiffs” and including the costs “associated” with their Reply Brief. 2 (Op. on URA Fees at 19).

The United States now opposes Plaintiffs’ amended fee request on both procedural and substantive grounds, primarily arguing that the demand exceeds the scope of the Court’s instructions and lacks sufficient evidentiary support. (Def.’s Resp. at 3–10). Specifically, the United States contends that Plaintiffs inappropriately included costs and fees incurred before August 11, 2025 (the day the United States’ prior responsive briefing was filed) and maintains that reimbursement is unavailable for work related to the appeal currently pending before the Federal Circuit. (Id. at 3–6). Furthermore, the United States asserts that the expenses associated with Plaintiffs’ reply brief were unnecessary because Plaintiffs allegedly refused to negotiate a resolution. (Id. at 6). Beyond these categorical objections, the United States argues that the fee award should be further reduced due to inaccuracies and vague entries within the billing records, which it claims are insufficient to allow for an objective assessment of reasonableness under the URA. (Id. at 7–10). The Court addresses each argument in turn.

The United States’ overarching contention is that the amended request improperly expands the scope of the original fee request, violating both the Court’s specific directives and general principles of fee-shifting. (Def.’s Resp. at 3–6). First, the United States believes it was improper that Plaintiffs included fees and costs in their amended motion that accrued before the

2 The Court also directed Plaintiffs not to file a reply brief in order to minimize their burden and avoid a continual accumulation of additional fees. (Op. on URA Fees at 19).

2 United States filed its Response on August 11, 2025. (Id. at 3–4). The United States points out that although the Court’s order limited additional fees to those “associated with” the Reply Brief, Plaintiffs’ demand reaches back to May 20, 2025, over a month before the Second Fee Motion was filed. (Id.). According to the United States, the only fees reasonably tied to the Reply are those incurred between the filing of the United States’ Response on August 11 and the filing of Plaintiffs’ Reply on August 25. (Id. at 4).

While the Court’s prior instruction specifically directed Plaintiffs to submit a fee request associated with their reply brief, (Op. on URA Fees at 18), that order must be interpreted within the broader context of equitable fee-shifting and the realities of this ongoing litigation. The Court acknowledges that its prior directive could have more clearly indicated that the amended request was to include fees incurred after the filing of the Second Fee Motion, rather than referring to them solely as fees associated with the reply brief. However, to construe the Court’s directive as limiting recovery strictly to the hours spent drafting the reply brief would create an artificial and illogical gap in the record, leaving the period between the initial motion and the final submission unaccounted for. This would be particularly inequitable given the full briefing and conference that occurred due to the United States’ Motion to Strike, (ECF No. 191). Capturing all fees and costs incurred since the Second Fee Motion is essential to making Plaintiffs whole and to preventing both a time-based windfall and the inefficiency of repeated supplemental filings.

Significantly, this clarification does not reopen the door to fees that could have been sought in the Second Fee Motion but were excluded.

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BRADLEY v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradley-v-united-states-uscfc-2026.