Summary
In this federal district court order, the court addresses a defendant's motion to compel acceptance of a default judgment amount and a plaintiff's motion for attorneys' fees and costs following a default judgment on FLSA and state wage claims. The court denied the defendant's motion, ruling that mandatory fee-shifting statutes require an award of reasonable attorneys' fees separate from damages. Applying the lodestar method, the court granted the plaintiff's motion, awarding $16,447.50 in attorneys' fees and $921.25 in costs based on reasonable hours and rates despite the defendants' dilatory conduct.
Topics
Practice areas
Questions Presented
- Whether the court must award attorneys' fees under the mandatory fee‑shifting provision of the FLSA.
- Whether the lodestar calculation may be adjusted downward based on novelty, skill, preclusion of other employment, or undesirability of the case.
- Whether the plaintiff is entitled to costs incurred in the litigation.
Holdings
- The court must award reasonable attorneys' fees because the plaintiff prevailed in an FLSA action and the statute makes such an award mandatory.
- The court will not reduce the lodestar for novelty, skill, preclusion of other employment, or undesirability; only factors not subsumed in the lodestar may adjust it, and none apply here.
- The court awards the plaintiff $921.25 in costs.
Key quotations
“The award of an attorney’s fee is mandatory if a plaintiff prevails in the FLSA action.” (398 F. Supp. 3d at 468)
“Trial courts need not, and indeed should not, become green‑eyeshade accountants. The essential goal in shifting fees (to either party) is to do rough justice, not to achieve auditing perfection.” (563 U.S. at 838)
Factual background
Stephen Jones, an employee, alleged that Vector Technology Systems LLC and its principals failed to pay $11,328 in wages owed under the Fair Labor Standards Act and Arizona law. The court entered a default judgment for that amount. After judgment, the defendants offered to pay the judgment plus interest, but the plaintiff sought additional attorneys' fees and costs.
Procedural history
Plaintiff sued for unpaid wages under the FLSA; the court entered a default judgment of $11,328; plaintiff sought attorneys' fees and costs; defendant moved to compel acceptance of the judgment amount; the court denied the motion and granted the fee and cost award.