Judge: Douglas W. Stern, Case: 21STCV28796, Date: 2022-10-24 Tentative Ruling



Case Number: 21STCV28796    Hearing Date: October 24, 2022    Dept: 68

Lucia Gonzalez v. FCA US LLC, et al., Case No. 21STCV28796

Tentative Ruling:

Motion for Award of Attorneys Fees – Song Beverly Act

BACKGROUND

This is an action arising from multiple defects in a new 2018 Chrysler Pacifica, purchased by Plaintiff on August 21, 2018.  On August 4, 2021, Plaintiff Lucia Gonzalez (“Plaintiff”) filed a complaint against Defendants FCA US LLC (“Defendant”), W & B Automotive, Inc. (Bravo), and Does 1 through 40 for (1) violation of Song-Beverly Act – breach of express warranty; (2) violation of Song-Beverly Act – breach of implied warranty; (3) violation of Song-Beverly Act – Section 1793.2; and (4) negligent repair.

On June 14, 2022, Plaintiff filed a notice of settlement of entire case.

On September 27, 2022, Plaintiff filed the instant motion for attorneys’ fees and costs.  Defendant filed opposition papers on October 11, 2022.  Plaintiff filed reply papers on October 17, 2022.

Moving Party Position

Plaintiff initially sought $34,000.50 in attorneys’ fees, a 1.5 lodestar multiplier of $17,000.25, and $3,561.71 in costs. Plaintiff asserts her counsel’s hourly rates and time billed are reasonable. Plaintiff contends she is entitled to the fees incurred in bringing this motion. Plaintiff argues a 1.5 fee multiplier is justified because of the contingent nature the case.

Opposition

Defendant argues the requested attorneys’ fees are unreasonable and excessive. Defendant alleges that Plaintiff’s counsel engaged in unsupported block billing, and it should be curtailed. Defendant argues that Plaintiff should not recover any fees for time spent drafting the motion to compel, claiming that the Court has already awarded Plaintiff reasonable fees. Defendant asserts that the time spent on the fee motion should be reduced. Defendant argues that Plaintiff should not recover any fees incurred in connection with the negligent repair claims against Defendant Bravo because no fees may be recovered from those. Defendant requests that the Court use its discretion to reduce Plaintiff’s counsel’s hourly rate. Defendant argues that the facts in this case do not warrant a multiplier and the Court should apply a negative multiplier.  Defendant does not recommended a specific reduced amount in attorney’s fees requested by Plaintiff. Instead, Defendant requests that Plaintiff’s motion be denied in its entirety, or that the amount be reduced by various suggestions made by Defendant. Defendant makes no substantive arguments against Plaintiff’s requested costs.

Reply

Plaintiff argues Defendant has failed to satisfy its burden of proof as to why the requested fees are unreasonable or unnecessary. Plaintiff argues that Defendant misrepresented the Court’s discretion as to reduction of a fee amount. Plaintiff contends that her counsel did not ignore Defendant’s settlement efforts. Plaintiff asserts that the hours billed for the work are reasonable, and that Plaintiff no-charged the time entries solely attributed to the claim against Bravo. Plaintiff reiterates that her counsel’s hourly rate is reasonable and that a multiplier is warranted in this case.

ANALYSIS

I. Attorneys’ Fees

A prevailing party in entitled to recover costs, including attorneys’ fees, as a matter of right. (CCP §§ 1032(a)(4), 1032(b), 1033.5.)   A buyer who prevails on a claim under the Song-Beverly Act is entitled to recover “a sum equal to the aggregate amount of costs and expenses, including attorney’s fees based on actual time expended, determined by the court to have been reasonably incurred by the buyer in connection with the commencement and prosecution of such action.” (Cal. Civ. Code, § 1794(d).)

The fee setting inquiry in California ordinarily begins with the “lodestar” method, i.e., the number of hours reasonably expended multiplied by the reasonable hourly rate.  A computation of time spent on a case and the reasonable value of that time is fundamental to a determination of an appropriate attorneys’ fee award.  The lodestar figure may then be adjusted, based on consideration of factors specific to the case, in order to fix the fee at the fair market value for the legal services provided. (Serrano v. Priest (1977) 20 Cal.3d 25, 49.)  Such an approach anchors the trial court’s analysis to an objective determination of the value of the attorney’s services, ensuring that the amount awarded is not arbitrary.  (Id. at 48, n.23.)  After the trial court has performed the lodestar calculations, it shall consider whether the hourly rate is reasonable, and then the lodestar figure may be adjusted, in order to fix the fee at the fair market value for legal services provided. (PLCM Group v. Drexler (2000) 22 Cal.4th 1084, 1095.)

The factors considered in determining the modification of the lodestar include “the nature and difficulty of the litigation, the amount of money involved, the skill required and employed to handle the case, the attention given, the success or failure, and other circumstances in the case.” (EnPalm, LLC v. Teitler Family Trust (2008) 162 Cal.App.4th 770, 774 [emphasis in original].)

Plaintiff initial motion seeks $34,000.50 in fees, $17,000.25 as a 1.5 fee multiplier, and $3,561.71 in costs.

Defendant argues that Plaintiff’s counsel’s hourly rates are excessive. The Court finds that Plaintiff’s counsel’s hourly rates of $695 for Mr. Wirtz, $400 and $500 for attorneys and $150-$250 for paralegals are reasonable given their experience and the locality of the services provided. (See Wirtz Decl., ¶¶ 13-25.)

Defendant further contends that the hours billed are unreasonable or excessive due to block billing, overbilling, use of templates, sanctions that were awarded for the motion to compel, and charges for work done in relation to the claim against Defendant Bravo.

With respect to entries referencing Plaintiff’s claim against Defendant Bravo for negligent repair, Plaintiff has explained that time entries solely attributable to this claim were no-charged, and those that were not no-charged were relevant to Plaintiff’s Song Beverly Act claims against Defendant. (Reply at pp. 6-7.) Plaintiff sought to discover information and documents generally related to the attempted repairs on the vehicle, as Defendant Bravo inspected the vehicle when Plaintiff began having problems with it. (Reply at p. 7; Barns Reply Decl., ¶ 3.) These fees are thus recoverable in this case.

Defendant asserts that the time entries for client communication are excessive because Plaintiff’s counsel spent 18 hours communicating with their client. Plaintiff argues in their reply that 18 hours of communication with the client over 16 months of litigation is not excessive because that amounts to just over an hour per month. (Reply at p. 4.) The Court finds that 18 hours for client communication is not excessive.

Defendant also requested that the $2,515.00 billed in connection with the Motion to Compel be deducted because Plaintiff was awarded sanctions in the amount of $1,500 in connection with the Motion to Compel. (Opposition at pp. 5-6.) Plaintiff argues that the standard is different for awarding sanctions versus recovery of fees, costs, and expenses under the Song Beverly Act. (Reply at p. 6.) The standard for discovery sanctions under CCP § 2023.010 is the misuse of the discovery process, while the standard for recovery under the Song Beverly Act is for all fees, costs, and expenses “reasonably incurred.” (Civ. Code § 1794(d)).)

What if the Court had granted the motion to compel but not awarded any discovery sanctions?  Would that dictate that the Court exclude the time spent on that discovery motion in its entirety when determining the Song-Beverly statutory “reasonable” fee?  Indeed, what if the motion to compel had been denied, and thus no fees awarded.  Would it be proper for the Court to exclude the time spent making the motion?  Such an outcome would not be appropriate.  Attorney’s fees awarded at the conclusion of a case to the successful party will inherently include fees for time spent fighting losing battles or skirmishes.  But fees are not awarded on a battle-by-battle basis.  This Court believes that the award of sanctions on a discovery motion does not preclude the award of the “balance” of such fees at the end of the case as a “reasonable” fee under the statute.  The Court declines to reduce the amount of fees by $2,515.00.

Additionally, Defendant argues that the amount that Plaintiff’s counsel billed for reviewing and replying to the opposition to this motion and for attending the hearing related to the motion is excessive. The final amount for this work requested by Plaintiff in its reply is $4,400. (Barns Reply Decl., Ex. A.) Given the issues raised in the Opposition, the amount (which is in line with the predicted amount of fees) is in the ballpark.

The original lodestar amount requested by Plaintiff was $34,000.50. The Court finds that to be a reasonable fee.

II. Lodestar Multiplier

Plaintiff seeks an additional $17,000.25 in attorney’s fees as a 1.5 multiplier enhancement for the contingency risk in this matter.

Relevant factors to determine whether an enhancement is appropriate include (1) the novelty and difficulty of the questions involved, (2) the skill displayed in presenting them, (3) the extent to which the nature of the litigation precluded other employment by the attorneys, (4) the contingent nature of the fee award. (Ketchum v. Moses (2001) 24 Cal.4th 1122, 1132.)

Defendant asserts that there is no basis for a fee enhancement in this case. The Court agrees. This is not a matter involving any complex or novel legal issues warranting a multiplier, nor did the matter require any special skill. While there is a risk factor present in the case due to the contingency nature of the representation, the Court finds that the rates charged by Plaintiff’s counsel reflects that risk.

The Court would note that the type of risk in a case such as this where statutory attorneys fees are involved is materially different from the risk associated with what may be called a “traditional contingency fee” case, such as a personal injury case.  In that type of case there is both the risk of losing on liability and also the risk that one might win liability, but recover an amount that results in a small fee.  (Conversely the recovery in such a case is not limited to a “reasonable fee”.)  In a case such as this, the amount of the recovery for the Plaintiff does not limit the amount of attorneys fees that shall be awarded.  Even a relatively small recovery for the Plaintiff may result in a dramatically larger award of attorney fees.

Further, the Court notes that there is no lack of interest in the Bar to representing Song-Beverly plaintiffs, strongly suggesting that there is no need to apply an upward multiplier in order to entice representation of aggrieved purchasers.

Plaintiff has failed to show that her counsel engaged in any actions different from the usual lemon law action. Therefore, Plaintiff’s request for the 1.5 lodestar multiplier is denied.

III. Costs

Plaintiff has requested $3,561.71 in costs. Defendant has not challenged the reasonableness of the costs. The Court grants Plaintiff’s request for costs.

Evidentiary Objections

Defendant’s objections to Plaintiff’s Exhibits C and D are OVERRULED.  (Plaintiff’s counsel states that he used the materials to determine what he believes to be an appropriate rate to charge.  That is of very limited value to the Court.)

As to Plaintiff’s objections, the Court would note that it is capable of discerning the “facts” to which the party attests and the argument that is included in the declaration of counsel.  The Court shall give the declaration such weight as it deserves.  Plaintiff’s Objections are OVERRULED as to Objections 1 - 20, and SUSTAINED as to Objections 21 - 29.

Conclusion

Based on the foregoing, Plaintiff’s motion is GRANTED.  Plaintiff is awarded attorneys’ fees in the amount of $34,000.50 and costs in the amount of $3,561.71.