lodestar analysis in Washington

17 Washington opinions name it 2 courts 1998–2026 6 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

Case	Followed	Cited
Mahler v. Szucsgreen wash · 1998 · cited in 8 Washington opinions naming this issue, 2009–2026 2 sentences 2017Mr. Berschauer argues that the trial court abused its discretion by refusing to base its fee award on a lodestar analysis, citing Mahler v. Szucs, 135 Wn.2d 398, 433 , 957 P.2d 632 , 966 P.2d 305 (1998) ("[C]ourts should be guided in calculating fee awards by the lodestar method."). 2012Mahler, 135 Wn.2d at 434 . ¶23 Here, although the trial court mischaracterized its authority on remand, it did not abuse its discretion in refusing to use the 1.5 multiplier request because the lodestar analysis it employed already contemplates the attorney’s skill and case complexity in arriving at its conclusions.	2	8
Mahler v. Szucsgreen wash · 1998 · cited in 6 Washington opinions naming this issue, 2009–2026 2 sentences 2026Mahler v. Szucs, 135 Wn.2d 398, 434 , 957 P.2d 632 , 966 P.2d 305 (1998), overruled on other grounds by Matsyuk v. State Farm Fire & Cas. 2017Mr. Berschauer argues that the trial court abused its discretion by refusing to base its fee award on a lodestar analysis, citing Mahler v. Szucs, 135 Wn.2d 398, 433 , 957 P.2d 632 , 966 P.2d 305 (1998) ("[C]ourts should be guided in calculating fee awards by the lodestar method.").	1	6
Spokane Co. v. State Ex Rel. Co. Comrs.green wash · 1998 · cited in 4 Washington opinions naming this issue, 2015–2026 2 sentences 2026Mahler v. Szucs, 135 Wn.2d 398, 434 , 957 P.2d 632 , 966 P.2d 305 (1998), overruled on other grounds by Matsyuk v. State Farm Fire & Cas. 2017Mr. Berschauer argues that the trial court abused its discretion by refusing to base its fee award on a lodestar analysis, citing Mahler v. Szucs, 135 Wn.2d 398, 433 , 957 P.2d 632 , 966 P.2d 305 (1998) ("[C]ourts should be guided in calculating fee awards by the lodestar method.").	1	4
Bowers v. Transamerica Title Insurancegreen wash · 1983 · cited in 4 Washington opinions naming this issue, 1998–2020 2 sentences 2009The Union had argued that its attorneys usually charged others a higher figure and that it was appropriate to apply that higher sum under a lodestar analysis. ¶17 The lodestar approach was first discussed by the Washington Supreme Court in detail in Bowers v. Transamerica Title Insurance Company, 100 Wn.2d 581, 593-601 , 675 P.2d 193 (1983). 2009The Union had argued that its attorneys usually charged others a higher figure and that it was appropriate to apply that higher sum under a lodestar analysis. ¶17 The lodestar approach was first discussed by the Washington Supreme Court in detail in Bowers v. Transamerica Title Insurance Company, 100 Wn.2d 581, 593-601 , 675 P.2d 193 (1983).	1	4
In re the Guardianship of Deckergreen washctapp · 2015 · cited in 3 Washington opinions naming this issue, 2016–2026 2 sentences 2016App. 429 , 446- 47, 353 P.3d 669 , review denied. 184 Wn.2d 1015 , 360 P.3d 818 (2015) (trial court was not required to conduct a lodestar analysis in determining an award of attorney fees as costs when determining compensation under the guardianship statute). 2016App. 429, 446-47 , 353 P.3d 669 , review denied. 184 Wn.2d 1015 , 360 P.3d 818 (2015) (trial court was not required to conduct a lodestar analysis in determining an award of attorney fees as costs when determining compensation under the guardianship statute).	1	3

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (17)

Case	Cited	Years
Blair v. Washington State University green wash · 1987 2 sentences 2026Orchard relies on the following language from the statute: In any action on a contract or lease entered into after September 21, 1977, where such contract or lease specifically provides that attorneys' fees and costs, which are incurred to enforce the provisions of such contract or lease, shall be awarded to one of the parties, the prevailing party, whether he or she is the party specified in the contract or lease or not, shall be entitled to reasonable attorneys' fees in addition to costs and necessary disbursements. 8 Hawkins calls our attention to Blair v. Washington State University, 108 W 2026Orchard relies on the following language from the statute: In any action on a contract or lease entered into after September 21, 1977, where such contract or lease specifically provides that attorneys' fees and costs, which are incurred to enforce the provisions of such contract or lease, shall be awarded to one of the parties, the prevailing party, whether he or she is the party specified in the contract or lease or not, shall be entitled to reasonable attorneys' fees in addition to costs and necessary disbursements. 8 Hawkins calls our attention to Blair v. Washington State University, 108 W	3	2009–2026
Chuong Van Pham v. Seattle City Light green wash · 2007 2 sentences 2015In a lodestar analysis, the court " should discount hours spent on unsuccessful claims, duplicated or wasted effort, or otherwise unproductive time." Chuong Van Pham v. Seattle City Light, 159 Wn.2d 527, 538 , 151 P. 3d 976 ( 2007). 2015In a lodestar analysis, the court “should discount hours spent on unsuccessful claims, duplicated or wasted effort, or otherwise unproductive time.” Chuong Van Pham v. Seattle City Light, 159 Wn.2d 527, 538 , 151 P.3d 976 (2007).	2	2015–2015
In Re Settlement/Guardianship of AGM green washctapp · 2010 2 sentences 2015App. 58, 79 , 223 P. 3d 1276 ( 2010). 2015App. 58, 79 , 223 P.3d 1276 (2010).	2	2015–2015
Chuong Van Pham v. City of Seattle green wash · 2007 2 sentences 2015In a lodestar analysis, the court " should discount hours spent on unsuccessful claims, duplicated or wasted effort, or otherwise unproductive time." Chuong Van Pham v. Seattle City Light, 159 Wn.2d 527, 538 , 151 P. 3d 976 ( 2007). 2015In a lodestar analysis, the court “should discount hours spent on unsuccessful claims, duplicated or wasted effort, or otherwise unproductive time.” Chuong Van Pham v. Seattle City Light, 159 Wn.2d 527, 538 , 151 P.3d 976 (2007).	2	2015–2015
In re the Settlement/Guardianship of A.G.M. green washctapp · 2010 2 sentences 2015Quick argues that a lodestar analysis is required even in this procedural context, citing In re Settlement/Guardianship of AGM, 154 Wn. 2015In AGM, the trial court used a lodestar analysis to reduce attoi'ney fees for a settlement guardian ad litem in a minor settlement case. 154 Wn.	2	2015–2015
Fluke Capital & Management Services Co. v. Richmond green wash · 1986 2 sentences 2009Fluke, 106 Wash.2d at 625 , 724 P.2d 356 ; Zink, 137 Wash.App. at 277 , 152 P.3d 1044 . 2009Fluke, 106 Wn.2d at 625 ; Zink, 137 Wn.	2	2009–2009
Zink v. City of Mesa neutral washctapp · 2007 2 sentences 2009Fluke, 106 Wash.2d at 625 , 724 P.2d 356 ; Zink, 137 Wash.App. at 277 , 152 P.3d 1044 . 2009App. 271 , 152 P.3d 1044 (2007), review denied, 162 Wn.2d 1014 (2008). ¶19 In awarding reasonable attorney fees, a trial court should have an objective basis for the award.	2	2009–2009
Zink v. City of Mesa green washctapp · 2007 2 sentences 2009However, no Washington case has expressly applied the lodestar analysis to an attorney fees award under RCW 4.84.185, although this court upheld an award under the statute using the lodestar methodology in Zink v. City of Mesa, 137 Wash.App. 271 , 152 P.3d 1029 1044 (2007), review denied, 162 Wash.2d 1014 , 178 P.3d 1033 (2008). ¶ 19 In awarding reasonable attorney fees, a trial court should have an objective basis for the award. 2009*However, no Washington case has expressly applied the lodestar analysis to an attorney fees award under RCW 4.84.185, although this court upheld an award under the statute using the lodestar methodology in Zink v. City of Mesa, 137 Wn.	2	2009–2009
State v. Horton neutral wash · 2008 2 sentences 2009However, no Washington case has expressly applied the lodestar analysis to an attorney fees award under RCW 4.84.185, although this court upheld an award under the statute using the lodestar methodology in Zink v. City of Mesa, 137 Wash.App. 271 , 152 P.3d 1029 1044 (2007), review denied, 162 Wash.2d 1014 , 178 P.3d 1033 (2008). ¶ 19 In awarding reasonable attorney fees, a trial court should have an objective basis for the award. 2009*App. 271 , 152 P.3d 1044 (2007), review denied, 162 Wn.2d 1014 (2008). ¶19 In awarding reasonable attorney fees, a trial court should have an objective basis for the award.	2	2009–2009
Boeing Company v. Sierracin Corporation green wash · 2000 2 sentences 2009E.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 (1998) (Mandatory Arbitration Rules); Boeing Co. v. Sierracin Corp., 108 Wn.2d 38 , 738 P.2d 665 (1987) (Trade Secrets Act, ch. 19.108 RCW); Blair v. Wash. State Univ., 108 Wn.2d 558 , 740 P.2d 1379 (1987) (Washington Law Against Discrimination, ch. 49.60 RCW). 2009E.g., Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 (1998) (Mandatory Arbitration Rules); Boeing Co. v. Sierracin Corp., 108 Wn.2d 38 , 738 P.2d 665 (1987) (Trade Secrets Act, ch. 19.108 RCW); Blair v. Wash. State Univ., 108 Wn.2d 558 , 740 P.2d 1379 (1987) (Washington Law Against Discrimination, ch. 49.60 RCW).	2	2009–2009
Keyes v. Bollinger green washctapp · 1982 2 sentences 2001A. Consumer Protection Act Claim “[T]he question of whether particular actions gave rise to a violation of the Consumer Protection Act is reviewable as a question of law.” Keyes v. Bollinger, 31 Wn. 2001A. Consumer Protection Act Claim "[T]he question of whether particular actions gave rise to a violation of the Consumer Protection Act is reviewable as a question of law." Keyes v. Bollinger, 31 Wash.App. 286, 289 , 640 P.2d 1077 (1982). *459 Under Washington's CPA, "[u]nfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce" are unlawful.	2	2001–2001
In Re the Detention of LaBelle green wash · 1986 2 sentences 2026App. 2d 766 , 773, 538 P.3d 309 (2023) (quoting In re Det. of LaBelle, 107 Wn.2d 196, 219 , 728 P.2d 138 (1986)). -7- No. 87913-8-I The trial court then entered detailed written findings of fact and conclusions of law specifically addressing the reasonableness of the hours requested, the reasonableness of the requested hourly rates, and the reasonableness of the total fee award based on the specific circumstances of the case. 2026App. 2d 766 , 773, 538 P.3d 309 (2023) (quoting In re Det. of LaBelle, 107 Wn.2d 196, 219 , 728 P.2d 138 (1986)). -7- No. 87913-8-I The trial court then entered detailed written findings of fact and conclusions of law specifically addressing the reasonableness of the hours requested, the reasonableness of the requested hourly rates, and the reasonableness of the total fee award based on the specific circumstances of the case.	1	2026–2026
Brown v. Vail green wash · 2010 1 sentence 2024Kitselman provides no argument as to either order and “[a] party that offers no argument -18- No. 86859-4-I/19 WE CONCUR: in its opening brief on a claimed assignment of error waives the assignment.” Brown v. Vail, 169 Wn.2d 318 , 336 n.11, 237 P.3d 263 (2010). -19-	1	2024–2024
Brown v. Vail green wash · 2010 1 sentence 2024Kitselman provides no argument as to either order and “[a] party that offers no argument -18- No. 86859-4-I/19 WE CONCUR: in its opening brief on a claimed assignment of error waives the assignment.” Brown v. Vail, 169 Wn.2d 318 , 336 n.11, 237 P.3d 263 (2010). -19-	1	2024–2024
State v. Wolter neutral wash · 2015 2 sentences 2016App. 429 , 446- 47, 353 P.3d 669 , review denied. 184 Wn.2d 1015 , 360 P.3d 818 (2015) (trial court was not required to conduct a lodestar analysis in determining an award of attorney fees as costs when determining compensation under the guardianship statute). 2016App. 429, 446-47 , 353 P.3d 669 , review denied. 184 Wn.2d 1015 , 360 P.3d 818 (2015) (trial court was not required to conduct a lodestar analysis in determining an award of attorney fees as costs when determining compensation under the guardianship statute).	1	2016–2016
Lamont v. Savio green wash · 2015 2 sentences 2016App. 429 , 446- 47, 353 P.3d 669 , review denied. 184 Wn.2d 1015 , 360 P.3d 818 (2015) (trial court was not required to conduct a lodestar analysis in determining an award of attorney fees as costs when determining compensation under the guardianship statute). 2016App. 429, 446-47 , 353 P.3d 669 , review denied. 184 Wn.2d 1015 , 360 P.3d 818 (2015) (trial court was not required to conduct a lodestar analysis in determining an award of attorney fees as costs when determining compensation under the guardianship statute).	1	2016–2016
State v. Weaver neutral wash · 2008 1 sentence 2009However, no Washington case has expressly applied the lodestar analysis to an attorney fees award under RCW 4.84.185, although this court upheld an award under the statute using the lodestar methodology in Zink v. City of Mesa, 137 Wash.App. 271 , 152 P.3d *1029 1044 (2007), review denied, 162 Wash.2d 1014 , 178 P.3d 1033 (2008). ¶ 19 In awarding reasonable attorney fees, a trial court should have an objective basis for the award.	1	2009–2009

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.84.185 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 43 (2011–2026) CA 37 (1989–2026) WY 23 (1989–2024) WA 17 (1998–2026) MD 15 (2003–2025) MI 9 (1998–2022) MN 9 (2009–2025) FL 7 (1990–2026) NJ 6 (1988–2025) SC 6 (2008–2022) NM 5 (2013–2024) CT 5 (2009–2018) OH 5 (2018–2024) KS 4 (2011–2024) CO 4 (2024–2026) MA 4 (2009–2024) IL 4 (1995–2017) VT 3 (2010–2014) WI 3 (2019–2021) IN 3 (1996–1998) MS 3 (1990–2002) RI 2 (2000–2005) VA 2 (1999–2011) TN 2 (2004–2004) NV 2 (2007–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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