Kight v. Crunchy Tobacco, Inc.

CourtDistrict Court, District of Columbia
DecidedFebruary 14, 2024
DocketCivil Action No. 2021-3189
StatusPublished

This text of Kight v. Crunchy Tobacco, Inc. (Kight v. Crunchy Tobacco, Inc.) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kight v. Crunchy Tobacco, Inc., (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NATHAN M. KIGHT et al.,

Plaintiffs, Civil Action No. 21-cv-3189-CKK-MAU v.

CRUNCHY TOBACCO, INC.,

Defendant.

MEMORANDUM OPINION AWARDING DEFENDANT’S ATTORNEY’S FEES

Before the Court is Defendant Crunchy Tobacco, Inc.’s (“Crunchy”) Petition for

Attorneys’ Fees. ECF No. 40. Plaintiffs Nathan M. Kight and Funnels, LLC (collectively

“Funnels”) oppose Crunchy’s request. ECF No. 44.

The fee award in this case stems from Crunchy’s Motion to Compel Discovery and for

Sanctions and Motion in Limine (“Motion”). ECF No. 32. In its Motion, Crunchy moved for

sanctions under Federal Rule of Civil Procedure 37 for Funnels’ alleged discovery violations. See

ECF No. 32 at 4-5. Funnels opposed the Motion and Crunchy’s request for sanctions. ECF No.

34.

The Court held a hearing on Crunchy’s Motion on July 14, 2023. At that time, the Court

gave both Parties an opportunity to be heard as to the discovery dispute and further provided

Funnels an opportunity to address whether its failure to comply with discovery was substantially

justified. During the hearing, the Court repeatedly questioned counsel for Funnels about why

Funnels had failed to comply with many of its discovery obligations. Counsel provided no

meaningful explanation, let alone substantial justification, for its failure to comply with discovery.

For a number of reasons, including Funnels’ admissions that its failure to comply with several of

1 its discovery obligations was not justified, the Court largely granted Crunchy’s Motion. See ECF

No. 39. The Court also awarded Crunchy the reasonable attorney’s fees and costs it had incurred

in bringing the Motion pursuant to Rule 37. See ECF No. 39. The Court further ordered Crunchy

to file its substantiation of fees, which it did on August 7, 2023. ECF No. 40. Upon consideration

of the Parties’ filings, including documentation supporting Crunchy’s fees and costs, the Court

hereby awards Crunchy its attorney’s fees and costs in the amount of $8,246.45.

DISCUSSION

I. The Court Rejects Funnels’ Attempt to Relitigate the Basis for the Fee Award.

Funnels raises a number of unavailing arguments challenging the underlying basis for the

fee award. First, Funnels argues that the “American Rule” on attorney’s fees prohibits the Court

from awarding Crunchy its reasonable fees and costs. ECF No. 44 at 3–4. Funnels is wrong. As

an initial matter, the Court has already awarded Crunchy its fees. ECF No. 39. The fact that

Crunchy filed its documentation supporting the award as a “motion” 1 does not change the posture

of the case and does not reopen any merits arguments as to why Crunchy should be granted its

fees. In any event, Funnels is wrong on the law. Rule 37 clearly authorizes this Court to award a

party its reasonable fees and costs in connection with a successful motion to compel. See Fed. R.

Civ. P. 37(a)(5). In fact, the Rule requires the Court to do so absent circumstances which are not

present here. See id.

1 Crunchy improperly filed its petition as a Motion for Attorney’s Fees. ECF No. 40. The Court has already awarded attorney’s fees, and as such, Crunchy was directed to simply file its substantiation of attorney’s fees. Id. at 2. For this reason, as set forth herein, the Court is not entertaining relitigation of the underlying basis for the fee award, as Funnels already had two opportunities to raise its merits arguments in opposition to any fee award: in its Opposition to the Motion and at the July 14, 2023 oral argument. 2 Second, Funnels makes a number of arguments regarding its alleged compliance with

discovery and Crunchy’s conduct during discovery. See ECF No. 44 at 6-10. This includes

Funnels’ complaint that Crunchy failed to follow the District Judge’s standing order on discovery

prior to filing its motion to compel. See id. at 8. Funnels’ arguments are not relevant at this stage,

as the Court has already ruled on the Motion to Compel and awarded fees. In all its protestations,

Funnels fails to provide any meaningful justification for its staggering failure to produce the

discovery at issue.

Upon granting a motion to compel, the Court must, “after giving an opportunity to be heard,

require the party . . . whose conduct necessitated the motion . . . to pay the movant’s reasonable

expenses incurred in making the motion, including attorney’s fees.” Fed. R. Civ. P. 37(a)(5)(A).

Therefore, the inquiry here is simple: are Crunchy’s expenses in making the Motion reasonable?

II. Crunchy’s Petition for Fees and Costs

The Court generally “enjoys substantial discretion in making reasonable fee

determinations.” Swedish Hosp. Corp. v. Shalala, 1 F.3d 1261, 1271 (D.C. Cir. 1993); see also

Beck v. Test Masters Educ. Servs., Inc., 289 F.R.D. 374, 382 (D.D.C. 2013) (stating district court

has broad discretion in determining an appropriate attorney’s fee award). It is the moving party’s

burden to prove that the requested fees and costs are reasonable. See CFTC v. Trade Exch. Network

Ltd., 159 F. Supp. 3d 5, 8 (D.D.C. 2015). The party requesting fees must provide documentation

justifying the request. See, e.g., Nat’l Ass’n of Concerned Veterans v. Sec’y of Def., 675 F.2d

1319, 1324-30 (D.C. Cir. 1982) (per curiam); see also Hensley v. Eckerhart, 461 U.S. 424, 433

(1983) (explaining evidence must be submitted that supports the hours worked). The Court retains

discretion to reduce the amount based on specific objections. DL v. District of Columbia, 256

F.R.D. 239, 243 (D.D.C. 2009); see also Donnell v. United States, 682 F.2d 240, 250 (D.C. Cir.

3 1982). When a court grants an award of attorney’s fees and costs under Rule 37, “the [i]nitial

estimate for attorneys’ fees is calculated by ‘multiplying the number of hours reasonably expended

on the litigation times a reasonable hourly rate.’” DL, 256 F.R.D. at 242 (quoting Blum v. Stenson,

465 U.S. 886, 888 (1984)). There is a strong presumption that this number—the lodestar figure—

represents a reasonable fee. Id.

A. Reasonableness of Crunchy’s Rates

The Court first considers whether the hourly rates charged in this case were reasonable.

To meet its burden to show that the requested rate is reasonable, a party must “‘produce satisfactory

evidence—in addition to the attorney’s own affidavits—that the requested rates are in line with

those prevailing in the community for similar services by lawyers of reasonably comparable skill,

experience and reputation.’” Eley v. District of Columbia, 793 F.3d 97, 100 (D.C. Cir. 2015)

(quoting Blum, 465 U.S. at 895 n.11). As this Circuit has held, a reasonable fee is one that is

“adequate to attract competent counsel, but that does not produce windfalls to attorneys.” West v.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Blum v. Stenson
465 U.S. 886 (Supreme Court, 1984)
Kevin West v. John Potter
717 F.3d 1030 (D.C. Circuit, 2013)
Ventura v. Bebo Foods, Inc.
738 F. Supp. 2d 8 (District of Columbia, 2010)
Beck v. Test Masters Educational Services, Inc.
289 F.R.D. 374 (District of Columbia, 2013)
Eley v. District of Columbia
793 F.3d 97 (D.C. Circuit, 2015)
Commodity Futures Trading Commission v. Trade Exchange Network Ltd.
159 F. Supp. 3d 5 (District of Columbia, 2015)
Donnell v. United States
682 F.2d 240 (D.C. Circuit, 1982)
Weisberg v. Webster
749 F.2d 864 (D.C. Circuit, 1984)
Cobell v. Babbitt
188 F.R.D. 122 (District of Columbia, 1999)
DL v. District of Columbia
256 F.R.D. 239 (D.C. Circuit, 2009)

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