Mowles v. Maine Comm'n on Govt. Ethics & Election Practices

Superior Court of Maine·Decided April 10, 2009·No. CUMap-06-35·Unpublished

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss -.. ' - .. ' . i \ ;) '_ " CIVIL ACTION

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DOCKET NO. AP-06-35

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MICHAEL D. MOWLES, JR., Petitioner

ORDER FOR AWARD OF

v. ATTORNEY'S FEES AND COSTS

MAINE COMMISSION ON GOVERNMENTAL ETHICS & ELECTION PRACTICES, Respondent

Before the Court is Petitioner's Motion for an Award of Attorney's Fees and Litigation Costs.

BACKGROUND

The substantive facts of this case are detailed in this Court's Order dated March

29,2007. Briefly, this case involves Petitioner Michael Mowles, Jr.'s ("Petitioner" or "Mowles") successful challenge to Maine's Endorsements of Political Candidates statute, 21-A M.R.S. § 1014-A (2008), for violations of his civil rights pursuant to 42 USc. § 1983 (2006).1 On October 21, 2008, the Law Court held that section 1014-A "is unconstitutional on its face because it imposes a burden on core political speech protected by the First Amendment without a compelling state interest in doing so." Mowles v. Comm'n on Governmental Ethics & Election Practices, 2008 ME 160, <JI 1, 958 A.2d 897, 899. On remand, Petitioner moves for an award of attorney's fees in the amount of $57,717.75. 2

I Petitioner's 80C appeal (Count I) was essentially withdrawn by the time the case reached the Law Court. The Law Court did not address Petitioner's "as applied" claim (Count III), but certainly the Law Court's hold ing that section 10 14-A is unconstitutional on its face encompasses this "as applied" claim. 2 This amount includes the attorneys' fees and expenses incurred by Zachary Heiden and David Lourie on both the merits of the case and the fee application. The litigation expenses are a small fraction ($430,25) of this request.

DISCUSSION

The Civil Rights Attorney's Fees Awards Act of 1976, 42 U.s.c. § 1988 provides, in relevant part: "In any action or proceeding to enforce a provision of [42 U.s.c. § 1983] ... the court, in its discretion, may allow the prevailing party, other than the United States, a reasonable attorney's fee as part of the costs ...." 42 U.s.c. § 1988(b).

There is no dispute that Petitioner is the "prevailing party" in this matter.

Accordingly, the Court must determine the "reasonable attorney's fee" to be paid by the Commission. Both parties agree that the Court must employ the "lodestar" approach in making this determination. Simply put, the lodestar method is a calculation whereby "the number of hours reasonably expended on the litigation [are] multiplied by a reasonable hourly rate." Hensley v. Eckerhart, 461 U.s. 424, 433 (1983). Although this amount can be adjusted, there is a "strong presumption" that the lodestar figure is the amount that should be awarded to the prevailing party. Blanchard v. Bergeron, 489 U.s. 87, 95 (1989).

Thus, this is a two-step analysis for the Court. First, the Court must determine how many hours the Petitioner's attorneys reasonably spent on the litigation. Second, the Court must determine the reasonable hourly rate for Petitioner's two attorneys. II. Reasonable Hours Expended "Hours that are not properly billed to one's client also are not properly billed to one's adversary pursuant to statutory authority." Hensley, 461 U.s. at 434 (quoting Copeland v. Marshall, 205 U. S. App. D. C. 390,401,641 F.2d 880, 891 (1980) (en banc) (emphasis in original)). Hence, "there is a distinction between hours actually spent on the litigation, and hours reasonably spent." Court Awarded Attorney Fees, Court Awarded Attorney Fees § 16.02[1] (Matthew Bender and Company, Inc. 2008) (emphasis

in original) (hereinafter "Court Awarded Attorney Fees"). Courts consider twelve factors in determining the number of compensable hours. The factors are:

(1) the time and labor required;

(2) the novelty and difficulty of the questions;

(3) the skill requisite to perform the legal service properly;

(4) the preclusion of other employment by the attorney due to acceptance of the case;

(5) the customary fee;

(6) whether the fee is fixed or contingent;

(7) time limitations imposed by the client or the circumstances;

(8) the amount involved and the results 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 v. Georgia Hwy. Exp. Inc., 488 F.2d 714, 717-19 (5th Cir. 1974); see also Poussard v. Commercial Credit Plan, 479 A.2d 881 (Me. 1984).3 Moreover, "the fee applicant bears the burden of establishing entitlement to an award and documenting the appropriate hours expended and hourly rates." Hensley, 461 U.s. at 437. "If fee applicants do not exercise billing judgment, courts are obligated to do it for them, to cut the amount of hours for which payment is sought, pruning out those that are excessive, redundant, or otherwise unnecessary." ACLU v. Barnes, 168 F.3d 423,428 (11th Cir. 1999) (internal quotation omitted). However, the "exercise of billing judgment does not inevitably require the elimination of hours. In short, counsel, may recover for every hour actually expended so long as every hour was 'expended reasonably.'" Court Awarded Attorney Fees § 16.02[5][a] (citing cases).

Courts can engage in a line-by-line analysis of the attorneys' timesheets submitted with the fee application or they can reduce the number of hours awarded in gross. See Gates v. Deukmejian, 987 F.2d 1392, 1400 (9th Cir. 1992) (holding that for

3These twelve factors were set forth to determine fee awards under section 706(k) of Title VII of the Civil Rights Act of 1964, 42 U.S.c. § 2000e-5(k), but are also applied to section 1988 fee awards. Blanchard, 489 U.S. at 91.

voluminous fee applications percentage reductions "are acceptable, and perhaps necessary, tools for district courts fashioning reasonable fee awards.").

The Commission challenges Petitioner's request for fees the attorneys incurred in four different types of activities: 1) the administrative hearing; 2) briefing; 3) oral argument; and 4) the motion practice. Each activity is addressed below. Finally, the Court separately addresses the attorney fees incurred in the course of the fee application.

A. Administrative Proceeding Prior to Section 1983 Litigation The Commission argues that Attorney Lourie's time spent before the Commission (18 hours) is not compensable because the "asserted injury to Mowles' First and Fourteenth Amendment rights that formed the basis of his section 1983 claims did not occur until the Commission took that final agency action." Resp. Br. at 6-7.

By the plain-language of section 1988, attorney's fees are only awarded for "any action or proceeding to enforce" a section 1983 claim. Further, the u.s. Supreme Court in Hensley interpreted this to mean attorney's fees incurred "on the litigation." 461 U.s. at 433. Under section 1988, a court may award attorney fees for time "spent on administrative proceedings to enforce the civil rights claim prior to the litigation." Lambert v. Fulton County, 151 F. Supp. 2d 1364, 1371 (N.D. Ga. 2000) (quoting North Carolina Dept. ofTransp. v. Crest Street Community Council, Inc., 479 U.s. 6, 15 (1986)). Quite clearly, mandatory administrative remedies fall within this category. E.g., New York Gaslight Club, Inc. v. Carey, 447 U.s. 54,71, (1980) (Title VII action). The Court may, however, refuse to award attorney's fees for optional administrative proceedings. For example, in Webb v. County Board of Education, the u.s. Supreme Court upheld the trial court's denial of fees for time spent at an administrative hearing challenging that a teacher's termination was racially motivated. 471 U.s. 234,241 (1985). The u.s.

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