Larry T. Long, L. Allan Long, and B. Virginia Long, in Their Capacities as Trustees of the Lawrence Allan Long Trust, the Charles Edward Long Trust, the Larry Thomas Long Trust and the John Stephen Long Trust D/B/A the Long Trusts v. Robert M. Griffin, Robert M. Griffin, Jr., Charles W. Conrad, Marvin Ogilvie, and Marie Ogilvie

Summary

The Supreme Court of Texas held that the Griffins did not provide legally sufficient evidence to support an attorney’s fee award under the lodestar method because they failed to show the time expended on specific tasks. The court also held that the contingency-fee method could not support the award because the final judgment provided no monetary relief other than attorney’s fees. The court reversed the court of appeals’ judgment and remanded for a redetermination of attorney’s fees, declining to reach the postjudgment-interest issue.

Holdings

1. A claimant using the lodestar method to prove attorney's fees must provide evidence of the services performed, who performed them, the hourly rate, when the services were performed, and the amount of time required for the work. General descriptions of litigation activities and aggregate hours are legally insufficient because they do not permit meaningful review of the reasonableness and necessity of the requested fees.
2. The contingency-fee method could not support the attorney's-fee award because the final judgment awarded no monetary relief other than attorney's fees.
3. The court did not reach the postjudgment-interest issue because it was remanding for consideration of additional evidence concerning attorney's fees.

Questions Presented

1. Whether legally sufficient evidence supported the amount of attorney's fees awarded under the lodestar method when the fee application did not identify the time expended on specific tasks.
2. Whether the contingency-fee arrangement could support the attorney's-fee award when the final judgment awarded no monetary relief other than attorney's fees.
3. Whether postjudgment interest should accrue from the original 2003 judgment or the later 2009 final judgment.

Disposition

reversed_and_remanded