Holiday Inn Club Vacations Incorporated v. Wisznia Company Incorporated

District Court, E.D. Louisiana·Decided March 25, 2025·No. 2:24-cv-00330·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

HOLIDAY INN CLUB VACATIONS CIVIL ACTION INCORPORATED

VERSUS NO. 24-330

WISZNIA COMPANY SECTION: “J”(2) INCORPORATED

ORDER AND REASONS Before the Court are a Motion for Attorney’s Fees and Costs (Rec. Doc. 33), filed by Plaintiff Holiday Inn Club Vacations Incorporated, and an opposition filed by Defendants Wisznia Company Incorporated and Marcel Wisznia (Rec. Doc. 39), to which Plaintiff has replied (Rec. Doc. 40). Having considered the motions and legal memoranda, the record, and the applicable law, the Court finds that the motion should be GRANTED. FACTS AND PROCEDURAL BACKGROUND Plaintiff moves in response to this Court’s Order and Reasons, in which Defendants were found liable for breach of parties’ Settlement Agreement. (Rec. Doc. 31). Therein, Plaintiff was directed to move for a reasonable attorney’s fee and cost award, as specified in the Settlement Agreement. Three days beyond their deadline, Defendants sought leave to file their opposition. Through the tardy opposition, Defendants generally argued that the attorney’s fee requested is too high. Citing separate litigation also involving Defendants, Alliance Funding Group v. Wisznia Co., No. 23-4039, 2025 WL 35005 (E.D. La. Jan. 6, 2025), they aver a fee amount of 20% of the defaulted settlement amount would be reasonable.

LEGAL STANDARD “State law controls both the award of and the reasonableness of fees awarded where state law supplies the rule of decision.” Mathis v. Exxon Corp., 302 F.3d 448, 461 (5th Cir. 2002). Under Louisiana law, attorney’s fees are recoverable only where authorized by statute or contract. Rivet v. State, Dep’t of Transp. & Dev., 96-145, p. 10 (La. 9/5/96), 680 So. 2d 1154, 1160. Here, the basis of Plaintiff’s fee award is

contractual. Specifically, the Settlement Agreement made fees and costs awardable for a party’s failure to comply with the agreement’s terms: “If any party should be required to file an action to enforce any provision of this Agreement, the prevailing party shall be entitled to attorneys’ fees and costs associated with the same.” (Rec. Doc. 26-2 at 43 ¶ 13). The Settlement Agreement, moreover, was confected in Louisiana and governed by the state’s laws. Id. at 43 ¶ 12. Accordingly, the Court will apply Louisiana law to Plaintiff’s request for attorney’s fees.

“An accepted method with which to begin calculation of a fee award under Louisiana law is to multiply the hours worked by an hourly rate the Court deems to be reasonable.” Bodin v. Butler, No. 07-3505, 2008 WL 5122354, at *5 (E.D. La. Dec. 4, 2008). The reasonableness of the award is governed by factors established in Rule 1.5 of Louisiana’s Rules of Professional Conduct. Chevron USA, Inc. v. Aker Mar. Inc., 689 F.3d 497, 505 (5th Cir. 2012). As the Fifth Circuit has observed, Louisiana’s fee

calculation factors are “very similar to those used in the federal ‘lodestar’ method as set out in Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir.1974).” Id. Any methodological difference between Louisiana and federal calculation is reduced even further where neither party objects to the method chosen. See Heck v.

Triche, 601 F. App’x 239, 242 (5th Cir. 2015). Here, on this Louisiana contract issue, both parties present arguments from the federal standard. The Court, in turn, will consider the fee issue in that context. In the Fifth Circuit, a two-step method determines the reasonable award of attorney’s fees. Combs v. City of Huntington, Texas, 829 F.3d 388, 391 (5th Cir. 2016). First, the court calculates the lodestar, the reasonable amount of hours for the work

multiplied by the prevailing community rate. Id. (citation omitted). This calculation yields a “strong presumption” of the reasonable fee. Heidtman v. Cnty. of El Paso, 171 F.3d 1038, 1044 (5th Cir. 1999) (citing City of Burlington v. Dague, 505 U.S. 557, 562 (1992)). Second, the court may exercise its discretion and adjust the lodestar based on the Johnson factors. Rodney v. Elliott Sec. Sols., L.L.C., 853 F. App’x 922, 924 (5th Cir. 2021). Johnson v. Georgia Highway Exp., Inc., 488 F.2d 714 (5th. Cir. 1974).

These factors include: (1) the time and labor required; (2) the novelty and difficulty of the issues presented; (3) the skill required to perform the legal skills properly; (4) the preclusion of other employment by the attorney due to acceptance of the case; (5) the customary fee; (6) whether the fee was fixed or contingent; (7) time limitations imposed by the client or the circumstances; (8) the amount involved and the result obtained; (9) the experience, reputation, and ability of the attorneys; (10) the undesirability of the case; (11) the nature and length of the professional relationship with the client; and (12) awards in similar cases.

Johnson, 488 F.2d at 717–19.1 A. THE NUMBER OF HOURS REASONABLY SPENT The Court must first determine if the hours requested by Plaintiff’s counsel were reasonable considering the nature of the case and the work performed. The party seeking fees bears the burden of proving the reasonableness of the requested hours. Mota v. Univ. of Tex. Houston Health Science Ctr., 261 F.3d 512, 528 (5th Cir. 2001) (citation omitted). Here, Plaintiff has requested $57,503.00 in attorney’s fees for 118.10 hours spent enforcing the Settlement Agreement. Aside from conclusory remarks about the excessive time spent, Defendants fail to present any meaningful analysis of Plaintiff’s submitted time sheets. In review of the record, the Court observes Defendants’ litigation behavior was the cause of increased billing time. Repeatedly, after periods of inaction, Defendants awoke to their rights, seeking tardy extensions of previously passed deadlines—beginning with permitting an entry of default against each

Defendant and then moving to set aside that default entry. And all this only accounts for litigation behavior from the filing of the First Amended Complaint—the time period pertinent to the fee award.

1 As previously noted, the Louisiana factors are similar: (1) the ultimate result obtained; (2) the responsibility incurred; (3) the importance of the litigation; (4) the amount of money involved; (5) the extent and character of the work performed; (6) the legal knowledge, attainment, and skill of the attorneys; (7) the number of appearances involved; (8) the intricacies of the facts involved; (9) the diligence and skill of counsel; and (10) the court’s own knowledge. Rivet, 680 So. 2d at 1161 (citing State, DOTD v. Williamson, 597 So. 2d 439, 441–42 (La. 1992)). The behavior is even more jarring when compared to the case Defendants marshal as support for their argument. In Alliance Funding Group v. Wisznia Co., Defendants, represented by different counsel, engaged in little of the above-cited

dilatory behavior. Significantly—faint but apt praise when compared to this litigation—Defendants timely answered the Complaint. All. Funding Grp. v. Wisznia Co., Inc., No.

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