Hammett v. Sherman

CourtDistrict Court, S.D. California
DecidedAugust 17, 2023
Docket3:19-cv-00605
StatusUnknown

This text of Hammett v. Sherman (Hammett v. Sherman) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hammett v. Sherman, (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 LAURA LYNN HAMMETT, Case No.: 19cv605-LL-AHG

12 Plaintiff, ORDER DENYING MOTIONS FOR 13 v. ATTORNEYS’ FEES

14 MARY E. SHERMAN, et al. [ECF Nos. 270, 271] 15 Defendants. 16 17 This matter is before the Court on the Motions for Attorneys’ Fees filed by 18 Defendants Patrick C. McGarrigle and McGarrigle, Kenney & Zampiello (together, the 19 “MKZ Defendants”) (the “MKZ Fee Motion”) [ECF No. 270], and by Defendants Ellis 20 Roy Stern, Alan N. Goldberg, Stern and Goldberg (together, the “S&G Defendants”) (the 21 “S&G Fee Motion”) [ECF No. 271] (collectively, the “Attorney Defendants” and the “Fee 22 Motions”). Plaintiff Laura Lynn Hammett filed an opposition to the MKZ Fee Motion 23 [ECF No. 285], an opposition to the S&G Fee Motion [ECF No. 286], and both the MKZ 24 Defendants [ECF No. 288] and S&G Defendants [ECF No. 287] filed replies to Plaintiff’s 25 oppositions. The Court finds this matter suitable for determination on the papers and 26 without oral argument pursuant to Federal Rule of Civil Procedure 78(b) and Civil Local 27 Rule 7.1.d.1. Upon review of the parties’ submissions and the applicable law, the Court 28 DENIES the Fee Motions WITHOUT PREJUDICE for reasons stated below. 1 I. BACKGROUND 2 Plaintiff originally brought claims for conversion and legal malpractice against the 3 Attorney Defendants in her first amended complaint (“FAC”). ECF No. 3 ¶¶ 264-303. The 4 Attorney Defendants filed special motions to strike or dismiss the claims against them in 5 Plaintiff’s FAC based on California’s anti-strategic lawsuit against public participation 6 (“anti-SLAPP”) statute [ECF Nos. 20, 21], and Plaintiff voluntarily dismissed her claims 7 against the Attorney Defendants under Rule 41(a)(1)(A)(i) [ECF No. 38]. The Court 8 dismissed the special motions to strike as moot [ECF No. 39], determined that the Attorney 9 Defendants were prevailing parties under the anti-SLAPP statute [ECF No. 111 at 46-48], 10 and awarded attorneys’ fees to the Attorney Defendants [id. at 49, 52]. Plaintiff 11 unsuccessfully appealed the attorney fee award [ECF Nos. 135, 144] and this Court denied 12 her motion for reconsideration of the fee order [ECF Nos. 177, 266]. Subsequently, the 13 Court granted the S&G Defendants’ ex parte motion to file a combined motion for 14 attorneys’ fees [ECF No. 267], and the Attorney Defendants then filed the instant Fee 15 Motions [ECF Nos. 270, 271]. Plaintiff moved to strike the Fee Motions for failure to 16 consolidate briefing according to the undersigned’s Civil Chambers Rules [ECF No. 282], 17 which the Court denied as incorrect [ECF No. 284]. Plaintiff’s appeal of the order granting 18 attorneys’ fees and the motion for reconsideration affirming that order is currently pending. 19 See ECF No. 273. 20 II. LEGAL STANDARD 21 California’s anti-SLAPP statute provides that “a prevailing defendant on a special 22 motion to strike shall be entitled to recover his or her attorney’s fees and costs.” Cal. Civ. 23 Proc. Code. § 425.16(c)(1); see also Ketchum v. Moses, 17 P.3d 735, 741 (Cal. 2001) 24 (“[A]ny SLAPP defendant who brings a successful motion to strike is entitled to mandatory 25 attorney fees.”). The fee provision of the anti-SLAPP statute includes compensation for 26 “‘all hours reasonably spent, including those necessary to establish and defend the fee 27 claim.’” Ketchum, 17 P.3d at 748 (quoting Serrano v. Unruh, 652 P.2d 985, 997 (Cal. 28 1982)). In other words, the provision is broadly construed as to effectuate the legislative 1 purpose of compensating defendants for the expense of responding and extracting 2 themselves from a SLAPP suit. See Wanland v. Law Ofcs. of Mastagni, Holstedt & 3 Chiurazzi, 45 Cal. Rptr. 3d 633, 637 (Ct. App. 2006) (citing Wilkerson v. Sullivan, 121 4 Cal. Rptr. 2d 275, 277 (Ct. App. 2002)). As such, section 425.16(c) has been interpreted to 5 include expenses incurred in litigating an award of attorney fees, Ketchum, 17 P.3d at 747, 6 in litigating an appeal, Morrow v. Los Angeles Unified Sch. Dist., 57 Cal. Rptr. 3d 885, 902 7 (Ct. App. 2007) (citation omitted), and in litigating a stay of the enforcement of a fee order, 8 Wanland, 45 Cal. Rptr. 3d at 637. 9 The award of fees and costs in an anti-SLAPP case must be reasonable, and courts 10 have broad discretion to determine what is reasonable. See Metabolife Int’l, Inc. v. 11 Wornick, 213 F. Supp. 2d 1220, 1222 (S.D. Cal. 2002). California courts apply the lodestar 12 approach for determining a reasonable fee award in an anti-SLAPP case. Ketchum, 17 P.3d 13 at 744; see also Champion Produce, Inc. v. Ruby Robinson Co., Inc., 342 F.3d 1016, 1024 14 (9th Cir. 2003) (“An award of attorneys’ fees incurred in a suit based on state substantive 15 law is generally governed by state law.”). For the lodestar approach, the Court begins by 16 fixing a lodestar by “multiplying the number of hours reasonably expended by counsel by 17 a reasonable hourly rate.” Lealao v. Beneficial California, Inc., 97 Cal. Rptr. 2d 797, 803 18 (Ct. App. 2000). The Court may then adjust the lodestar amount based on factors including 19 “(1) the novelty and difficulty of the questions involved, (2) the skill displayed in 20 presenting them, (3) the extent to which the nature of the litigation precluded other 21 employment by the attorneys, [and] (4) the contingent nature of the fee award.” Ketchum, 22 17 P.3d at 741 (citing Serrano v. Priest, 569 P.2d 1303, 1316 (Cal. 1977)). 23 In determining what “elements . . . should comprise a determination of the 24 reasonable hourly value of an attorney’s services,” California courts look to the reasoning 25 in federal cases as “both persuasive and appropriate for consideration.” Margolin v. Reg’l 26 Plan. Comm’n, 185 Cal. Rptr. 145, 147 (Ct. App. 1982) (noting that the California Supreme 27 Court in Serrano v. Priest “cited and relied on many federal decisions in promulgating the 28 California rules” related to awarding attorneys’ fees). To determine a reasonable hourly 1 rate, the Court looks to the “rate prevailing in the community for similar work performed 2 by attorneys of comparable skill, experience, and reputation.” Camacho v. Bridgeport Fin., 3 Inc., 523 F.3d 973, 979 (9th Cir. 2008) (internal quotation marks and citation omitted). In 4 this case, the relevant community is the Southern District of California because it is “the 5 forum in which the district court sits.” Id. The burden is on the party requesting attorneys’ 6 fees to produce “satisfactory evidence, in addition to the affidavits of its counsel, that the 7 requested rates are in line with those prevailing in the community for similar services of 8 lawyers of reasonably comparable skill and reputation.” Jordan v. Multnomah Cnty., 815 9 F.2d 1258, 1263 (9th Cir. 1987) (citing Blum v. Stenson, 456 U.S. 886, 895-97 (1984)). 10 Evidence that the Court should consider includes “[a]ffidavits of the [movant’s] attorney 11 and other attorneys regarding prevailing fees in the community, and rate determinations in 12 other cases, particularly those setting a rate for the [movant’s] attorney[.]” United 13 Steelworkers of Am. v. Phelps Dodge Corp., 896 F.2d 403, 407 (9th Cir. 1990).

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Serrano v. Unruh
652 P.2d 985 (California Supreme Court, 1982)
Serrano v. Priest
569 P.2d 1303 (California Supreme Court, 1977)
Camacho v. Bridgeport Financial, Inc.
523 F.3d 973 (Ninth Circuit, 2008)
Margolin v. Regional Planning Commission
134 Cal. App. 3d 999 (California Court of Appeal, 1982)
Wanland v. Law Offices of Mastagni, Holstedt & Chiurazzi
45 Cal. Rptr. 3d 633 (California Court of Appeal, 2006)
Christian Research Institute v. Alnor
165 Cal. App. 4th 1315 (California Court of Appeal, 2008)
Lealao v. Beneficial California, Inc.
97 Cal. Rptr. 2d 797 (California Court of Appeal, 2000)
Morrow v. Los Angeles Unified School District
57 Cal. Rptr. 3d 885 (California Court of Appeal, 2007)
ComputerXpress, Inc. v. Jackson
113 Cal. Rptr. 2d 625 (California Court of Appeal, 2001)
Metabolife International, Inc. v. Wornick
213 F. Supp. 2d 1220 (S.D. California, 2002)
Rawlinson v. Cheyenne Board of Public Utilities
2001 WY 6 (Wyoming Supreme Court, 2001)
Ketchum v. Moses
17 P.3d 735 (California Supreme Court, 2001)
Concepcion v. Amscan Holdings, Inc.
223 Cal. App. 4th 1309 (California Court of Appeal, 2014)
Champion Produce, Inc. v. Ruby Robinson Co.
342 F.3d 1016 (Ninth Circuit, 2003)
United Steelworkers v. Phelps Dodge Corp.
896 F.2d 403 (Ninth Circuit, 1990)

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Hammett v. Sherman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hammett-v-sherman-casd-2023.