Robert Maddaus v. Edwards

CourtDistrict Court, W.D. Washington
DecidedFebruary 7, 2025
Docket3:18-cv-05387
StatusUnknown

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

Bluebook
Robert Maddaus v. Edwards, (W.D. Wash. 2025).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 ROBERT MADDAUS, CASE NO. 18-cv-5387 BHS 8 Plaintiff, ORDER 9 v. 10 JAMES EDWARDS and EDITH KROHA, 11 Defendant. 12

13 THIS MATTER is before the Court on plaintiff Robert Maddaus’s motion for 14 attorneys’ fees, Dkt. 251. 15 Maddaus seeks attorneys’ fees and costs under 42 U.S.C. § 1988(b) as the 16 prevailing party on his § 1983 claims against defendants Edwards and Kroha. He 17 acknowledges the Prison Litigation Reform Act (PLRA) presumptively limits the hourly 18 rate of a lodestar attorneys’ fee award. That amount is 150% of the PLRA hourly rate, 19 ($164 in 2023, $172 in 2024). The PLRA presumptive maximum rate was $258 per hour 20 for the bulk of the work performed on the case. Dkt. 251 at 3–5 (citing 42 U.S.C. § 21 1997e); Dkt. 258 at 4. The PLRA also caps the total fee award at 150% of the judgment, 22 1 which does not apply here, and provides that 25% of a fee award must come from the 2 plaintiff’s judgment; $100,500 in this case. Id.

3 Maddaus has submitted detailed timekeeping records documenting the hours his 4 Court-appointed attorneys spent representing him in 2023 and 2024. Dkt. 252 at 6–16. At 5 the PLRA-limited rates, these hours amount to $157,869.60 in attorneys’ fees. Id. at 16. 6 He seeks an enhancement of these fees (increasing the rates to the attorneys’ reasonable, 7 “normal” rates) based on the exceptional result obtained— a judgment twenty times the 8 amount offered—and because the attorneys obtained it on a very short timeline. Dkt. 251

9 at 2 (citing Kelly v. Wengler, 822 F.3d 1085, 1100–03 (9th Cir. 2016)). Maddaus seeks 10 $252,251.50 in attorneys’ fees, which is about a 1.6 multiplier of the PLRA capped 11 lodestar fees. Maddaus’s motion seeks $9,486.62 in costs, for a total of $261,738.12. Dkt. 12 251 at 1. 13 Maddaus’s Reply asserts that his attorneys spent an additional 60.6 hours on the

14 fee motion and in successfully responding to defendants’ motion for judgment as a matter 15 of law. Dkt. 260 at 7 (citing Mennemier Declaration, Dkt. 261). 16 Defendants do not oppose an award of fees under § 1988 and the PLRA, and do 17 not strenuously1 dispute the hours Maddaus’s attorneys spent. They do argue that 18 “nothing about the law, facts, or posture of this warrants an enhancement” above the

19 PLRA hourly rates. Dkt. 258 at 2. 20 1 Defendants assert that Maddaus’s attorneys logged and submitted 28.6 hours that 21 expressly reflected administrative tasks or that were unclear about whether they reflected legal or administrative trial preparations. They advocate for a $7,378.80 deduction from the PLRA 22 lodestar amount. Dkt. 258 at 5 n.2. 1 DISCUSSION 2 A. Attorneys’ Fees

3 The first step in determining reasonable attorneys’ fees in any case is to calculate 4 the lodestar figure. This figure is the number of hours reasonably expended on the 5 litigation multiplied by the reasonable hourly rate for such work. See Hensley v. 6 Eckerhart, 461 U.S. 424, 433 (1983). The Court should exclude overstaffed, redundant, 7 or unnecessary time. Id. at 434. The plaintiffs’ success is a “crucial factor” in determining 8 an appropriate award. Id. at 440.

9 Defendants do not dispute that the vast bulk of the time Maddaus’s attorneys spent 10 on this case was reasonable, and the Court finds that it was. 11 In cases free of the PLRA cap, the Court determines reasonable hourly rates by 12 looking to the “prevailing market rates in the relevant community.” Bell v. Clackamas 13 County, 341 F.3d 858, 868 (9th Cir. 2003). This usually involves an evaluation of the

14 hourly rates of comparable attorneys in the forum district. See Gates v. Deukmejian, 987 15 F.2d 1392, 1405 (9th Cir. 1992). The Court should also consider the experience, skill, and 16 reputation of the attorney requesting fees. Schwarz v. Sec’y of Health & Human Servs., 17 73 F.3d 895, 906 (9th Cir. 1995). It may rely on its own knowledge and familiarity with 18 the legal market in determining a reasonable hourly rate. Ingram v. Oroudjian, 647 F.3d

19 925, 928 (9th Cir. 2011). 20 Maddaus demonstrates, and based on its experience in other attorney fee disputes 21 the Court is persuaded, that Maddaus’s attorneys’ “usual” billing rates are reasonable. 22 Dkt. 252. 1 The issue is whether the Court should lift the PLRA’s presumptive hourly rate cap 2 ($258 per hour for most of time spent on this case) and calculate Maddaus’s fee award

3 instead using his attorneys’ higher, reasonable hourly rates. 4 Maddaus accurately asserts that in determining whether to modify PLRA lodestar 5 fees the Court looks to the so-called Kerr factors. Dkt. 251 at 4 (citing Kelly, 822 F.3d at 6 1099, and Edmo v. Corizon, Inc., 97 F.4th 1165 (9th Cir. 2024) (“the [Kerr] standard 7 broadly governing when to give enhancements under § 1988 . . . applies equally to PLRA 8 cases.”)). The Court views the request for fees above the PLRA hourly rate as akin to a

9 request for a fee award above the attorney’s customary rate. 10 Under Kerr, once the Court determines the lodestar amount, it determines whether 11 to adjust the lodestar figure up or down, based on factors not subsumed in that figure. The 12 Kerr factors are: 13 (1) the time and labor required,

14 (2) the novelty and difficulty of the questions involved, 15 (3) the skill requisite to perform the legal service properly, 16 (4) the preclusion of other employment by the attorney due to acceptance of the 17 case, 18 (5) the customary fee,

19 (6) whether the fee is fixed or contingent, 20 (7) time limitations imposed by the client or the circumstances, 21 (8) the amount involved and the results obtained, 22 (9) the experience, reputation, and ability of the attorneys, 1 (10) the ‘undesirability’ of the case, 2 (11) the nature and length of the professional relationship with the client, and

3 (12) awards in similar cases. 4 Kerr v. Screen Extras Guild, Inc., 526 F.2d 67, 69-70 (9th Cir. 1975), cert. denied, 425 5 U.S. 951 (1976). Maddaus argue that the five bolded factors weigh in favor of lifting the 6 PLRA cap, and that none weigh against. Dkt. 251 at 7. 7 The fifth Kerr factor, “customary fee,” plainly supports lifting the stay, but the 8 PLRA cap implicitly acknowledges that the rate charged in its absence would,

9 customarily, be more. Defendants fairly point out that some portion of counsel’s 10 customary rate reflects intellectual property expertise that was not at play in this case. 11 Dkt. 258 at 8. Maddaus’s attorneys’ litigation experience and conduct in the case 12 supports their rates. The fact that they typically do other types of work for the rates they 13 charge weighs in favor of an enhanced fee award in this case. This issue is addressed

14 below. Kerr’s customary fee factor does not weigh heavily in the Court’s determination 15 of whether to lift the PLRA cap. 16 The seventh Kerr factor, “time constraints,” firmly supports lifting the cap. 17 Maddaus’s attorneys accepted the Court’s appointment as Maddaus’s pro bono counsel 18 less than six months before they obtained a substantial verdict in his favor, in a case that

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Joshua Kelly v. Timothy Wengler
822 F.3d 1085 (Ninth Circuit, 2016)
Bell v. Clackamas County
341 F.3d 858 (Ninth Circuit, 2003)
Kerr v. Screen Extras Guild, Inc.
526 F.2d 67 (Ninth Circuit, 1975)
Adree Edmo v. Corizon, Inc.
97 F.4th 1165 (Ninth Circuit, 2024)

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Robert Maddaus v. Edwards, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-maddaus-v-edwards-wawd-2025.