Second Circuit Reverses Trial Court; Grants Additional Attorney Fees
In this action, Rizwan Raja, a longtime industry representative entitled to appear for clients at the OATH Taxi and Limousine Tribunal, was awarded summary judgment on his claim that defendants' suspension of his right to practice without a hearing denied him due process of law. Following that judgment, Raja and defendants agreed to a settlement of the damages aspect of his case, which awarded him $20,001 plus reasonable attorney's fees. The District Court concluded that Raja was the prevailing party and awarded him fees. But the court also reduced by 40 percent the number of hours to be compensated due to “several deficiencies” in counsel's time charges. The court also refused to order any compensation for time counsel spent on a closely related administrative hearing, which served as discovery in the federal action and which allowed Raja to prevail on summary judgment.
The Court of Appeals held that the district court erred by reducing the fee award due to "block billing," by finding certain time entries vague and by deeming Raja's success in the action “partial.” As a result of these findings, the court imposed an across-the-board cut in hours that was plainly disproportionate to any defects in the billing records or the level of success. The court also erred by denying any fees for time spent on an administrative hearing that took place after the federal action commenced and which was essential to enforcing Raja's federal civil rights claim.
This was major victory as attorney fees decisions are rarely successfully appealed and because the Court did so in a full, precedent-setting decision.
Practice area(s): Civil Litigation
Court: Second Circuit Court of Appeals