United Pool Distribution, Inc. v. Custom Courier Solutions, Inc.

District Court, W.D. New York·Decided April 15, 2025·No. 6:22-cv-06314·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

UNITED POOL DISTRIBUTION, INC., Plaintiff, Case # 22-CV-06314-FPG v. DECISION AND ORDER CUSTOM COURIER SOLUTIONS, INC.,

Defendant.

INTRODUCTION On February 4, 2025, the Court granted Plaintiff’s motion for attorney’s fees, costs, and expenses, finding that Defendant and Defendant’s counsel did not act in good faith and were substantially unprepared to participate in the mediation session held on January 3, 2025, in violation of Federal Rule of Civil Procedure Rule 16(f)(1)(B). ECF No. 86. The Court asked Plaintiff’s counsel to submit its fees, costs, and expenses to the Court and opposing counsel for review. Id. Plaintiff requests $58,425.35 in fees, costs, and expenses. ECF Nos. 89, 90. Defendant argues that Plaintiff’s request should be significantly reduced. ECF No. 93. For the reasons that follow, the Court concludes that Plaintiff shall be awarded $11,020.00 in fees, costs, and expenses. DISCUSSION Defendant disputes both the reasonableness of the rates charged by Plaintiff’s attorneys as well as the reasonableness of the hours expended by Plaintiff’s attorneys. See ECF No. 93. The Court discusses each in turn. I. Reasonable Rate The parties disagree about what constitutes a reasonable rate for Plaintiff’s attorneys. Plaintiff maintains that its out-of-district rate, ranging between $250 per hour for paralegals to $660 per hour for partners, is reasonable because when a party hires counsel from within its own 1 district, it is presumptively reasonable. ECF No. 94 at 6–7. As both Plaintiff and its counsel are from the Southern District of Ohio, Plaintiff argues that the Court should apply its out-of-district rate. Id. at 7. However, Defendant argues that Plaintiff’s attorneys’ rates are well in excess of the rates within this district and that Plaintiff has failed to show why it should be awarded an out-of-

district rate. ECF No. 93 at 9. Essentially, Defendant argues that the Court should apply the forum rule when calculating fees in this case. The forum rule provides that courts “should generally use the hourly rates employed in the district in which the reviewing court sits in calculating the presumptively reasonable fee.” Simmons v. N.Y.C. Transit Auth., 575 F.3d 170, 174 (2d Cir. 2009) (quotation and internal quotation marks omitted). The principal objective of awarding attorney’s fees as sanctions is to deter sanctionable conduct. See Caisse Nationale de Credit Agricole–CNCA, New York Branch v. Valcorp, Inc., 28 F.3d 259, 266 (2d Cir. 1994); On Time Aviation, Inc. v. Bombardier Capital, Inc., 354 F. App’x 448, 452 (2d Cir. 2009) (summary order). Accordingly, district courts have discretion in determining the rate for attorney’s fees awarded as sanctions and are not bound by the forum rule

or other presumptions, which apply when calculating attorney’s fees in other contexts. See Ceglia v. Zuckerberg, 10-CV-00569, 2012 WL 503810, at *7 (W.D.N.Y. Feb. 14, 2012); On Time Aviation, Inc., 354 F. App’x at 452 (concluding that the reasoning behind the calculation of awards under fee-shifting statutes is not “precisely analogous” to that applicable to sanctions awards). In this case, the Court concludes that calculating attorney’s fees using the hourly rates typically employed in this district is adequate for deterring further sanctionable conduct, and therefore the Court will use the prevailing rates in this district when calculating the award. See McCullough v. World Wrestling Entertainment, Inc., No. 15-CV-1074, 2021 WL 4472719, at *3 (D. Conn. Sept. 30, 2021). 2 “[D]etermination of a reasonable hourly rate ‘contemplates a case-specific inquiry into the prevailing market rates for counsel of similar experience and skill to the fee applicant’s counsel,’ an inquiry that may ‘include judicial notice of the rates awarded in prior cases and the court’s own familiarity with the rates prevailing in the district.’” Townsend v. Benjamin Enters., Inc., 679 F.3d

41, 59 (2d Cir. 2012) (quoting Farbotko v. Clinton County, 433 F.3d 204, 209 (2d Cir. 2005)). Based upon this Court’s familiarity with the prevailing hourly rates in this district and rates awarded in prior cases within this district, the Court finds that rates of $300 per hour for partners, $200 per hour for associate attorneys, and $100 per hour for paralegals are the appropriate rates for this award. See Ortiz v. Stambach, 657 F. Supp. 3d 243, 269 (W.D.N.Y 2023) (finding rates of $300 per hour for experienced attorneys, $200 per hour for associates, and $100 per hour for paralegals reasonable hourly rates in this district); Warr v. Liberatore, No. 13-CV-6508, 2022 WL 969528, at *5 (W.D.N.Y. Mar. 31, 2022) (collecting cases and finding a $295 per hour rate reasonable for an experienced attorney in this district). Consequently, the Court will apply those rates when calculating the award amount.

II. Reasonableness of Hours and Expenses The parties also disagree about the reasonableness of the hours Plaintiff’s counsel expended on this case. Plaintiff argues that the hours are reasonable. ECF No. 94 at 8. However, Defendant believes that the hours should be reduced by half as a “practical means of trimming fat from a fee application.” ECF No. 93 at 10. Defendant also argues that Plaintiff should not recover any of the travel expenses it seeks because they would not have incurred those expenses if Plaintiff had hired counsel in this district. Id. at 8. Again, the principal objective of awarding attorney’s fees and expenses as sanctions is to deter sanctionable conduct. See Caisse Nationale de Credit Agricole–CNCA, New York Branch, 28 3 F.3d at 266. In this case, the Court sanctioned Defendant and Defendant’s counsel because they did not act in good faith and were substantially unprepared to participate in the mediation session, which unnecessarily delayed the resolution of this matter in violation of Rule 16(f)(1)(B). ECF No. 86 at 5. Pursuant to Rule 16(f)(2)

[i]nstead of or in addition to any other sanction, the court must order the party, its attorney, or both to pay the reasonable expenses—including attorney’s fees— incurred because of any noncompliance with this rule, unless the noncompliance was substantially justified or other circumstances make an award of expenses unjust.

Fed. R. Civ. P. 16(f)(2). Therefore, the Court must award reasonable expenses incurred due to Defendant’s failure to act in good faith and failure to prepare for the mediation session, but it is not required to award expenses that Plaintiff would have incurred regardless of Defendant’s noncompliance with Rule 16. In this case, the Court concludes that it is appropriate to only award Plaintiff fees, costs, and expenses related to Defendant’s actions at the mediation session. Many of the hours submitted by Plaintiff’s counsel relate to work that is not a result of Defendant’s sanctionable conduct. For instance, Plaintiff’s first entry, for time analyzing “court order on CCS summary judgment motion,” would have needed to be completed regardless of Defendant’s sanctionable conduct. See ECF No. 90-1 at 2. The Court believes that it would be inappropriate to award fees based on work that Plaintiff would have had to needed to complete regardless of Defendant’s noncompliance, as an award of expenses related to Defendant’s noncompliance is adequate to deter future sanctionable conduct.

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United Pool Distribution, Inc. v. Custom Courier Solutions, Inc., (W.D.N.Y. 2025).

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