EASTERLING v. COUNTY OF DELAWARE

District Court, E.D. Pennsylvania·Decided May 22, 2025·No. 2:23-cv-05016·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

DARICK EASTERLING : CIVIL ACTION : v. : : COUNTY OF DELAWARE : NO. 23-5016

MEMORANDUM Bartle, J. May 22, 2025 The court has before it the motion of plaintiff Darick Easterling “seeking the award of attorneys’ fees and expenses” pursuant to 42 U.S.C. § 12205 (Doc. # 77). Plaintiff sued his employer, defendant County of Delaware, for wrongfully discriminating against him on the basis of his disability, for failing to accommodate his disability, and for retaliating against him in violation of the Americans with Disabilities Act, 42 U.S.C. § 12101, et seq. (“ADA”), and the Pennsylvania Human Relations Act, 43 Pa. Stat. § 951, et seq. (“PHRA”). He also pleaded claims under the Family & Medical Leave Act, 29 U.S.C. § 2601, et seq. (“FMLA”).1 On February 13, 2025, this court granted summary judgment in defendant’s favor

1. Under the FMLA, plaintiff alleged that defendant interfered with his ability to exercise his FMLA rights, discriminated against him for exercising those rights, and retaliated against him. on these claims. See Memorandum (E.D. Pa. Feb. 13, 2025) (Doc. # 45); see also Memorandum (E.D. Pa. Feb. 26, 2025) (Doc. # 62). Thereafter, a jury trial was held on the remaining

claims. The jury found that Delaware County wrongfully discriminated against plaintiff on the basis of his disability and failed to accommodate his disability in violation of the ADA and PHRA.2 The jury, however, also found that Easterling failed to prove his claim that Delaware County retaliated against him in violation of the ADA and the PHRA. The jury awarded plaintiff $1 in compensatory damages, that is damages for pain and suffering caused by Delaware County’s unlawful conduct. Thereafter, the court held a non- jury trial on damages and added $92,690.30 in back pay, prejudgment interest of $4,538.12, and $105,347.96 in front pay in lieu of reinstatement. Together with the $1 awarded by the

jury, the court entered a judgment in favor of plaintiff in the amount of $202,577.38 (Doc. # 75). I The court has the discretion under 42 U.S.C. § 12205 to “allow the prevailing party, other than the United States, a

2. Although the state law claim was not mentioned to the jury, the parties stipulated that the jury’s determination as to plaintiff’s federal law claim would also control as to his PHRA claim because the two statutes are coextensive, at least for the purposes of liability. See Kelly v. Drexel Univ., 94 F.3d 102, 105 (3d Cir. 1996). reasonable attorney’s fee, including litigation expenses, and costs” in actions brought pursuant to the ADA. Similarly, the PHRA provides that “[i]f, after a trial . . . the court . . .

finds that a defendant engaged in or is engaging in any unlawful discriminatory practice as defined in this act, the court may award attorney fees and costs to the prevailing plaintiff.” See 43 Pa. Stat. § 962(c.2). A court may only award attorneys’ fees when the prevailing party was successful on any significant issue in the litigation and obtains a benefit sought in the suit. Hensley v. Eckerhart, 461 U.S. 424, 433 (1983). Plaintiff, as the party seeking fees, has the burden of proof to show he prevailed. See, e.g., Hare v. Potter, 549 F. Supp. 2d 698, 702 (E.D. Pa. 2008). A court has discretion to determine what attorneys’

fee is reasonable. See Hensley, 461 U.S. at 433. Generally, courts use the “lodestar” method, wherein the court calculates attorneys’ fees by multiplying the number of hours reasonably expended on an action by a reasonable hourly rate. See Washington v. Phila. Cnty. Ct. of Common Pleas, 89 F.3d 1031, 1035 (3d Cir. 1996). Again, plaintiff bears the burden to prove that his request is reasonable. Rode v. Dellarciprete, 892 F.2d 1177, 1183 (3d Cir. 1990). To be reasonable, hours must not be “excessive, redundant or otherwise unnecessary.” See id.; see also Pub. Int. Rsch. Grp. of N.J. v. Windall, 51 F.3d 1179, 1188 (3d Cir.

1995). Work on an unsuccessful claim may be deducted from the total amount of reasonable hours to the extent that it may be distinguishable as a unique claim for relief “based on different facts and legal theories.” Hensley, 461 U.S. at 434-35. Plaintiff prevailed in this action. The jury found in his favor on his claims of discrimination and retaliation in violation of the ADA and PHRA. He was awarded $202,577.38 in damages. Plaintiff submitted evidence to recover $169,410 in fees for the work of his attorney Edward Sweeney, Esq., a partner at Wusinich, Sweeney, & Ryan, LLC. Plaintiff calculated this amount by multiplying 228.01 hours of work by a proposed

rate of $750 per hour. Plaintiff further seeks $12,525 in attorneys’ fees for the work of M. Frances Ryan, Esq., a partner at Wusinich, Sweeney, & Ryan, for her 16.7 hours of work multiplied by her proposed rate of $750 per hour. In total, plaintiff requests the court award him $181,935 in attorneys’ fees. Defendant argues that the court should deduct any hours that plaintiff’s counsel spent litigating his FMLA or retaliation claims as these claims were ultimately unsuccessful and therefore the work expended on these claims was unnecessary. Defendant specifically proposes that the court deduct

18.94 hours for the work on plaintiff’s FMLA claims. These hours were spent drafting plaintiff’s trial memorandum in opposition to defendant’s position on the successor-in-interest issue under the FMLA and then litigating his unsuccessful motion for reconsideration on the court’s grant of summary judgment in favor of defendant on plaintiff’s FMLA claims. These hours are distinct from plaintiff’s attorneys’ work on his successful claims. Thus these 11.04 hours worked by Mr. Sweeney and 7.9 hours worked by Ms. Ryan were not reasonable and will be deducted from the total hours worked. See Loughner v. Univ. of Pittsburgh, 260 F.3d 173, 178 (3d Cir. 2001). Defendant also identifies 16.34 hours that plaintiff’s

counsel spent solely on his ultimately unsuccessful claims of retaliation. It proposes that the court should deduct all this time. The hours were expended almost exclusively on successfully opposing the motion of Delaware County for summary judgment on these claims. Deducting these hours does not appropriately credit plaintiff’s counsel for its work. The court finds that the time that plaintiff’s counsel spent opposing defendant’s unsuccessful motion was reasonable even though the jury found against plaintiff on the issue of retaliation. The court finds that it was reasonable for Mr. Sweeney

to work 216.97 hours and for Ms. Ryan to work 8.8 hours, the hours after deducting the 18.94 hours worked in relation to plaintiff’s FMLA claims. In total, that is 225.77 hours. Easterling’s counsel litigated the case through trial and otherwise presented sufficiently detailed records of their work by hour.

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EASTERLING v. COUNTY OF DELAWARE, (E.D. Pa. 2025).

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