Wolfgang Olson v. Northwest Motorsport, Inc. and Northwest Motorsport, LLC

District Court, W.D. Washington·Decided May 28, 2026·No. 2:20-cv-01616·Unknown

Opinion

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3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 WOLFGANG OLSON, 8 Plaintiff, 9 v. C20-1616 TSZ 10 NORTHWEST MOTORSPORT, INC. ORDER and NORTHWEST MOTORSPORT, 11 LLC, 12 Defendants. 13 THIS MATTER comes before the Court on Plaintiff’s Motion for Award of 14 Reasonable Attorney’s Fees, docket no. 147. Having reviewed all papers filed in support 15 of, and in opposition to, the motion, the Court enters the following order. 16 Background 17 On June 12, 2024, the Court entered its Amended Judgment, docket no. 138, in 18 this action in favor of Plaintiff Wolfgang Olson against Defendants Northwest 19 Motorsport, Inc. and Northwest Motorsport, LLC (collectively, “Defendants”), in the 20 total amount of $289,171.41. The Court previously awarded Plaintiff reasonable 21 attorney’s fees for prevailing at trial, pursuant to the Washington Consumer Protection 22 Act (“CPA”), RCW 19.86.090, and the “prevailing party” attorney fee provision of the 1 “Vehicle Buyer’s Order” for the truck purchased by Plaintiff from Defendants. See 2 Conclusions of Law at ⁋ 50 (docket no. 111); see also Order at 2, 10 (docket no. 137).

3 On November 6, 2025, Defendants filed a motion, docket no. 139, to vacate the Amended 4 Judgment as void pursuant to Federal Rule of Civil Procedure 60(b)(4), contending that the 5 Court lacked subject matter jurisdiction in this matter following the dismissal of the claims of former plaintiffs Seth Villafan and Josh Graves on June 14, 2023, because Plaintiff Olson failed 6 to plead and prove complete diversity. See Mot. at 7–8, 14–16 (docket no. 139). On November 7 17, 2025, Defendants filed an amended motion, docket no. 141, to vacate the Amended 8 Judgment, asserting the same argument. See Mot. at 7–8, 14–16 (docket no. 141). The motions 9 will hereafter be referred collectively to as the “motion to vacate.” On January 6, 2026, the 10 Court denied the motion to vacate. Minute Order at 1 (docket no. 146). On January 20, 2026, 11 Plaintiff filed a motion for an award of reasonable attorneys’ fees for successfully defeating 12 Defendants’ motion to vacate. See Mot. at 2–4 (docket no. 147). 13 Discussion 14 Defendants argue that (1) Plaintiff’s motion for attorneys’ fees should be denied in 15 its entirety because there is no basis to award fees, and (2) even if Plaintiff is entitled to 16 attorneys’ fees, the requested amount should be reduced substantially. Opp. at 1 (docket 17 no. 152). The Court addresses each argument in turn. 18 A. Entitlement to attorneys’ fees 19 Defendants contend that neither the CPA nor the attorney fee provision in the 20 parties’ contract offer a basis for an award of attorneys’ fees in these circumstances. 21 Opp. at 1 (docket no. 152). The Court disagrees. 22 1 “The general rule in Washington is that attorney fees will not be awarded for costs 2 of litigation unless authorized by contract, statute, or recognized ground of equity.”

3 Durland v. San Juan Cnty., 182 Wn.2d 55, 76, 340 P.3d 191 (2014). Plaintiff again relies 4 on RCW 19.86.090 and the “prevailing party” attorney’s fee provision of the “Vehicle 5 Buyer’s Order” as bases for being entitled to his request. 6 The CPA permits an award of attorney fees to the prevailing party. RCW 7 19.86.090 (“That such person may bring a civil action in the district court to recover his 8 or her actual damages . . . including reasonable attorney’s fees.”). Where a contract

9 specifically provides that attorneys’ fees shall be awarded to one of the parties, whether 10 he or she is the party specified in the contract or not, the prevailing party “shall be 11 entitled to reasonable attorneys’ fees.” RCW 4.84.330. “Prevailing party” means the 12 party in whose favor final judgment is entered. Id. The “Vehicle Buyer’s Order” 13 contains a prevailing party attorney’s fees shifting provision: “In any litigation regarding

14 this Agreement, Buyer shall reimburse Dealer for all reasonable attorney fees and court 15 costs should Dealer prevail.” Findings of Fact at ⁋ 21 (docket no. 111); Ex. 1 at ⁋ 22 to 16 Beckett Decl. (docket no. 148 at 16). 17 The Ninth Circuit has held that a party was entitled, pursuant to a contractual 18 provision, to attorney fees for defending against a Rule 60(b)(3) motion to vacate an

19 arbitration award. Lafarge Conseils Et Etudes, S.A. v. Kaiser Cement & Gypsum Corp., 20 791 F.2d 1334, 1340–41 (9th Cir. 1986). In Lafarge, arbitrators awarded monetary 21 damages in relation to a lawsuit based on breach of contract, and the district court 22 awarded attorney fees after denying a motion to vacate the award. Id. at 1337. The 1 parties’ contract contained an attorney fees provision, entitling the party to an award of 2 fees “in any action to enforce the contract.” Id. The defendant challenged the fee award

3 on appeal, arguing that its motion to vacate was based on a right granted by federal 4 procedure, not state substantive law, and thus the fee provision of the contract did not 5 apply. See id. at 1340. The Ninth Circuit rejected that argument, because the underlying 6 contract between the parties was not “collateral to the proceedings” but played an integral 7 part in defining the rights of the parties by setting forth arbitration as the agreed means of 8 dispute resolution. Id. (distinguishing In re Johnson, 756 F.2d 738 (9th Cir. 1985)).

9 Plaintiff is entitled to attorneys’ fees pursuant to the fee provision in the Vehicle 10 Buyer’s Order. Although Defendants grounded their Rule 60(b)(4) motion on the theory 11 that the Court lacked subject matter jurisdiction, the underlying “Vehicle Buyer’s Order” 12 played an integral role in defining the rights of the parties and led directly to the entry of 13 the Amended Judgment after the Court’s finding of liability. Therefore, the “Vehicle

14 Buyer’s Order” was not collateral to the proceedings of Defendants’ motion to vacate.1 15 B. Amount to be awarded 16 The Court now decides the reasonableness of Plaintiff’s attorneys’ fees request. 17 Plaintiff requests a total of $46,678.00 for defending against Defendants’ motions to 18

20 1 Defendants also contend that Plaintiff’s motion for fees should be denied because the merger doctrine 21 forecloses recovery. Opp. at 6 (docket no. 152). Under the merger doctrine, “when ‘a valid and final judgment for the payment of money is rendered in favor of the plaintiff, the original claim of the plaintiff 22 is extinguished and a new cause of action on the judgment is substituted for it.’” Johnson v. Peter, 2023 WL 22021, at *11 (W.D. Wash. Jan. 3, 2023) (quoting Restatement (Second) of Judgments § 47)). The 1 vacate and filing a reply brief in support of its motion for fees. See Amended Reply at 2 7–8 (docket no. 156); Ex. 1 at 4 to Amended Reply (docket no. 156-1).

3 The reasonableness of an attorney’s fees request is evaluated using the lodestar 4 method. Collins v. City First Mortg. Servs., LLC, 177 Wn. App. 908, 927, 317 P.3d 5 1047 (2013) (citation omitted). Under the lodestar method, the Court must determine the 6 reasonable number of hours expended on a matter, excluding any “wasteful or duplicative 7 hours and any hours pertaining to unsuccessful theories or claims” from the total. Id.

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Wolfgang Olson v. Northwest Motorsport, Inc. and Northwest Motorsport, LLC, (W.D. Wash. 2026).

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