State Farm Mutual Automobile Insurance Company v. Angelo

CourtDistrict Court, E.D. Michigan
DecidedMay 29, 2025
Docket3:19-cv-10669
StatusUnknown

This text of State Farm Mutual Automobile Insurance Company v. Angelo (State Farm Mutual Automobile Insurance Company v. Angelo) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Farm Mutual Automobile Insurance Company v. Angelo, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Case No: 19-10669 Plaintiff, Honorable Nancy G. Edmunds v.

MICHAEL ANGELO, et al.,

Defendants. _________________________________/

OPINION AND ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF ATTORNEY FEES AND COSTS

On September 14, 2023, the Honorable Robert H. Cleland granted Plaintiff State Farm Mutual Automobile Insurance Company’s (“State Farm”) motion for award of attorney fees and costs, awarding State Farm its costs and fees incurred in connection with enforcing the parties’ Confidential Settlement Agreement and Release (“Settlement Agreement”). (ECF No. 197.) This case was then transferred to the undersigned, and this Court issued an order denying Plaintiff’s motion to seal information relating to attorney rates and denying Defendant Michael Angelo’s motion to stay proceedings pending resolution of his appeal of the order granting Plaintiff’s motion for attorney fees and costs.1 (ECF No. 206.) Consistent with this Court’s order, Plaintiff submitted an amended bill of costs, which is the subject of this order. (ECF No. 207.) Plaintiff’s bill of costs includes work from two law firms within the local Michigan market, Miller, Canfield, Paddock and Stone, P.L.C. (“Miller Canfield”) and Riley Safer Holmes & Cancila LLP

1 Defendant’s appeal of the order granting attorney fees and costs was denied and dismissed for lack of jurisdiction. (ECF No. 209.) (“RSHC”), and one based in Washington, D.C., Morgan, Lewis & Bockius LLP (“Morgan Lewis”). Id. Defendant filed an objection to the bill of costs. (ECF No. 208.) The Court will decide the matter without a hearing pursuant to Eastern District of Michigan Local Rule 7.1(f). For the reasons set forth below, Plaintiff’s attorney fees and costs are

GRANTED IN PART and DENIED IN PART. I. Legal Standard To calculate a reasonable award for attorney fees, courts use the lodestar method, “which is calculated by multiplying the number of hours reasonably expended on the litigation by a reasonable hourly rate.” Imwalle v. Reliance Med. Prods., 515 F.3d 531, 551 (6th Cir. 2008). “To justify an award of attorneys’ fees, the party seeking compensation bears the burden of documenting its work.” Gonter v. Hunter Valve Co., 510 F.3d 610, 617 (6th Cir. 2007). “The key requirement for an award of attorney fees is that ‘[t]he documentation offered in support of the hours charged must be of sufficient detail and probative value to enable the court to determine with a high degree of

certainty that such hours were actually and reasonably expended in the prosecution of the litigation.’" Imwalle, 515 F.3d at 553 (alteration in original) (quoting United Slate Local 307 v. G&M Roofing & Sheet Metal Co., 732 F.2d 495, 502 n.2 (6th Cir. 1984)). Furthermore, the party seeking a fee award should identify the general subject matter for each time entry. Id. (citing Cleveland Area Bd. of Realtors v. City of Euclid, 965 F. Supp. 1017, 1020 (N.D. Ohio 1997)). Finally, to determine a reasonable attorney’s fee award, courts normally “look to the hourly rates prevailing in the community for similar services by lawyers of reasonably comparable skill, experience, and reputation.” Fuhr v. Sch. Dist. of Hazel Park, 364 F.3d 753, 762 (6th Cir. 2004). However, where, as here, “fees are sought for an out-of-town specialist, courts must determine (1) whether hiring the out-of-town specialist was reasonable in the first instance, and (2) whether the rates sought by the out-of-town specialist are reasonable for an attorney of his or her degree of skill, experience, and reputation.” Hadix v. Johnson, 65 F.3d 532, 535 (6th Cir. 1995).

II. Analysis A. Out-of-town Counsel As Judge Cleland put it, this has been an “extensive litigation” where the “post- settlement life . . . rivals the scope of its pre-settlement’s.” (ECF No. 197, PageID.9112.) Post-settlement actions taken by Defendant in violation of the Settlement Agreement include filing an amended complaint in the qui tam action, which alleged widespread fraud by Plaintiff under the False Claims Act. (ECF No. 149, PageID.8070.) There was then additional time spent on enforcing Defendant’s obligation under the Settlement Agreement to solicit the Government’s consent to dismiss Plaintiff from the qui tam action and determining whether Defendant adequately did so before Defendant followed through

under protest. (ECF No. 197, PageID.9113.) Due to the nationwide scope of the allegations and potential liability involved in Defendant’s pursuit of the qui tam action and the close monitoring and numerous steps needed to be taken to ensure Defendant discharged his Settlement Agreement obligations, the Court finds Plaintiff has shown it was reasonable to hire out-of-town specialists.2 The Court also finds the rates requested by the Morgan Lewis attorneys to be reasonable. Due to the alternative fee arrangement in place between Morgan Lewis and

2 The Court also notes that the out-of-town counsel from Morgan Lewis have extensive litigation experience and national reputation regarding False Claim Act claims. (ECF No. 207-3, PageID.10164- 66.) Plaintiff, the effective average hourly rate of its attorneys was $743.59.3 This is less than the ninety-fifth percentile hourly rate charged by attorneys located in Downtown Detroit ($760). (ECF No. 198-5, PageID.9299.) Considering the experience and reputation of the Morgan Lewis attorneys in this area of litigation, an hourly rate somewhere in the top

tenth percentile of a relevant local market is reasonable. B. Lodestar The Court has reviewed the billing entries for each law firm and finds, with one exception, the hours requested reasonable. Defendant argues each firm’s billing entries includes several hours with insufficient detail for Plaintiff to show the hours charged were reasonably related to the litigation. (ECF No. 208, PageID.10572.) Defendant focuses on entries with information redacted for privilege to descriptions as limited as “discuss,” “revise,” or “attend.” Id. at 10573. However, the supporting documentation for attorney fee requests are “taken as a whole” when considering its adequacy, and “explicitly detailed descriptions are not required.” Imwalle, 515 F.3d at 554. In their bill of costs and attached

declarations, Plaintiff has provided sufficient documentation to inform the Court of the subject matter of the activities involved in the billing entries and that the hours billed were actually and reasonably spent enforcing the Settlement Agreement even if the billing entries on their own do not always do so. (See ECF Nos. 207; 207-2; 207-3; 207-4.) The bill of costs and supporting documentation here are similar to that found adequate in Imwalle. There, the Sixth Circuit upheld a fee award with a bill of costs containing entries as vague as “conference with,” “research,” and “review documents” because the billing records, as here, were itemized and specified the date, the time, and the individual who

3 This number is reached by dividing the fee award requested ($918,559.83) by the total number of hours billed in connection with enforcing the parties’ Settlement Agreement (1,235.3).

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State Farm Mutual Automobile Insurance Company v. Angelo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-farm-mutual-automobile-insurance-company-v-angelo-mied-2025.