Smail Company, Inc. v. Liberty Mutual Auto and Home Services, LLC, et al.

CourtDistrict Court, W.D. Pennsylvania
DecidedOctober 16, 2025
Docket2:23-cv-02056
StatusUnknown

This text of Smail Company, Inc. v. Liberty Mutual Auto and Home Services, LLC, et al. (Smail Company, Inc. v. Liberty Mutual Auto and Home Services, LLC, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smail Company, Inc. v. Liberty Mutual Auto and Home Services, LLC, et al., (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

SMAIL COMPANY, INC., ) ) Plaintiff, ) ) vs ) Civil Action No. 23-2056 ) Judge Stickman ) Magistrate Judge Dodge LIBERTY MUTUAL AUTO AND HOME ) SERVICES, LLC, et al., ) ) Defendants. )

MEMORANDUM ORDER

Plaintiff Smail Company, Inc. has filed a Verified Petition for Fees Pursuant to This Court’s Order Dated August 13, 2025 (ECF No. 106) and Defendants have filed a response in opposition (ECF No. 117). For the reasons that follow, Plaintiff’s motion for attorney’s fees will be granted in part and denied in part. I. Relevant Procedural History On July 3, 2025, Plaintiff filed a motion for sanctions (ECF No. 88), which was based on the instruction directed by counsel for Defendants to Greg Alway, Defendants’ Rule 30(b)(6) witness, not to answer certain questions posed by Smail at a deposition on June 11, 2025.1 A Memorandum Order was subsequently entered (ECF No. 93) that granted Plaintiff’s motion in part. In the Order, the Court concluded that Defendants improperly instructed Mr. Alway not to answer two questions during this deposition.2 Plaintiff provided no authority for certain relief it sought, which was striking Defendants’ Answer and New Matter. However, the Court determined

1 This was the second deposition of Mr. Alway. 2 Plaintiff did not identify the questions that Mr. Alway was instructed not to answer but attached several pages from the deposition. Based on its review of these pages, the Court determined that two questions were not answered. Neither party has disputed this conclusion. that Plaintiff could seek reasonable attorney’s fees as a sanction. Plaintiff was directed to submit a petition for attorney’s fees and costs to which it claimed to be entitled. Defendants first moved for reconsideration of the Court’s order but then appealed the sanctions order (ECF No. 108) to the district judge, rendering the reconsideration motion moot. On September 5, 2025, Judge Stickman issued an Order (ECF No. 114) that affirmed this Court’s sanctions order.3

Plaintiff has submitted a petition for fees (ECF No. 106), which it later supplemented. (ECF No. 116). Defendants have filed a response in opposition to the petition (ECF No. 117). II. The Parties’ Positions Plaintiff seeks the recovery of various categories of fees and costs, including the time spent preparing the initial motion for sanctions and reviewing Defendants’ response; time incurred for preparing the fee petition; time spent reviewing Defendants’ motion for reconsideration; time spent reviewing and responding to Defendants’ “exceptions”; two-fifths of the travel time to the deposition in Dallas, Texas; and costs that include a rental car and two-fifths of the cost of a hotel room.4 Plaintiff indicates that the total time spent on these activities was 27 hours, which when

multiplied by its counsel’s hourly rate of $375.00, results in requested attorney’s fees of

3 In its motion for sanctions, Plaintiff did not ask to take a third deposition of Defendants’ designee and as a result, the Court stated in its order that fact discovery had closed. Plaintiff then filed a “Motion for Clarification” (ECF No. 97), in which it argued that it had previously sought an extension of discovery for the (implied) purpose of conducting a third deposition. On August 14, 2025, the Court issued a Memorandum Order explaining that pursuant to the Federal Rules of Civil Procedure, Plaintiff could not conduct a third deposition of Mr. Alway without the agreement of opposing counsel or a court order. Plaintiff then filed a “Motion for Leave to Conduct Third Deposition of Defendants” (ECF No. 105), which Defendants opposed (ECF No. 111). The Court has ruled on Plaintiff’s motion (ECF No. 118). 4 Plaintiff explains that it multiplied the travel time and hotel cost by a fraction of 2/5 because it contends that Mr. Alway’s second deposition lasted approximately three hours but would have lasted five hours if he had been properly prepared and had not been instructed not to answer certain questions. (ECF No. 106 at 3.) The fee petition describes the claimed travel time as follows: “Based on flight time to and from Dallas, travel time to Pittsburgh airport. Due to personal reasons the Plaintiff’s counsel actually drove to Dallas.” $10,125.00, plus $110.00 in costs, consisting of 2/5 of a hotel room at $150.00, or $60.00, and $50.00, the cost one day of car rental. Thus, the total fees and costs requested is $10,235.00. Defendants oppose Plaintiff’s fee petition in its entirety on several grounds. First, they contend that Plaintiff improperly seeks fees such as travel time and expenses for counsel’s trip to Dallas despite the fact that the Court indicated in its order that the deposition could take place

remotely. Second, they contend that the petition is not supported by contemporaneous time records, which is not required but is “the preferred practice.” Clemens v. New York Cent. Mut. Fire Ins. Co., 903 F.3d 396, 401 (3d Cir. 2018) (citation omitted). Defendants also argue that Plaintiff has not demonstrated that the hourly rate of its counsel is “reasonable in light of the prevailing rates ‘in the community for similar services by lawyers of reasonably comparable skill, experience, and reputation.’” Id. at 402 (quoting Maldonado v. Houstoun, 256 F.3d 181, 184 (3d Cir. 2001)). In addition, Defendants object to the fees sought on the ground that, “When a party submits

a fee petition, it is not the ‘opening bid in the quest for an award.’” Id. at 403 (citation omitted). In this context, they reference a communication from Plaintiff’s counsel that was made before submitting the fee petition.5 Finally, Defendants contend that the hours expended on certain activities is excessive.

5 Defendant states that Plaintiff’s counsel made an offer to resolve the issue for $3,950.00, accompanied by the following statement: “I will file the petition and while I will likely not get every penny it is a good bet I will get far more than what an amicable resolution would cost.” (ECF No. 101-4 at 1, 2.) III. Discussion As an initial matter, and contrary to Defendants’ argument, the facts in this case do not resemble those that formed the basis for the Third Circuit’s decision in Clemens. In Clemens, the Court of Appeals held that a district court did not abuse its discretion when it denied a fee petition in its entirety. The Court’s decision was based on a number of factors that included the following:

(1) the court’s lodestar calculation reduced the requested fee by eighty-seven percent; (2) counsel did not maintain contemporaneous records but instead “recreated” records through estimates; (3) many of the time entries were vague; (4) some of the entries were unnecessary and excessive; (5) counsel failed to establish a basis for their rates or their reasonableness in the community; and (6) the fee petition did not distinguish which attorney performed each task. The Third Circuit concluded that these deficiencies justified the district court’s decision to deny the entire fee request. Id. at 403. The court did not hold, however, that when a court reduces a fee petition, it must deny the petition entirely. In fact, the Court of Appeals more recently stated that “only in drastic cases that rise to the level of attorney fraud or stupefying negligence and

exploitation has our Court completely denied the fees incurred in preparing a motion for attorneys’ fees.” Pocono Mountain Sch. Dist. v. T. D., 2023 WL 2983501, at *6 (3d Cir. Apr. 18, 2023). As Plaintiff notes in its Petition, the Court has consideration discretion in determining the amount of a fee award.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Bernie Clemens v. New York Central Mutual Fire I
903 F.3d 396 (Third Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Smail Company, Inc. v. Liberty Mutual Auto and Home Services, LLC, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/smail-company-inc-v-liberty-mutual-auto-and-home-services-llc-et-al-pawd-2025.