lodestar analysis in Minnesota

2025Based on its consideration of the factors in the second part of the lodestar analysis, the district court may “enhance or decrease the lodestar amount, although ‘many of these 15 factors usually are subsumed within the initial calculation of hours reasonably expended at a reasonable hourly rate.’” Krause, 925 N.W.2d at 33 (quoting Hensley, 461 U.S. at 434 & n.9). “[T]he amount involved and the results obtained must be addressed in the initial lodestar calculation when determining the reasonable number of hours expended.” Id. (quotation omitted).

2025Based on its consideration of the factors in the second part of the lodestar analysis, the district court may “enhance or decrease the lodestar amount, although ‘many of these 15 factors usually are subsumed within the initial calculation of hours reasonably expended at a reasonable hourly rate.’” Krause, 925 N.W.2d at 33 (quoting Hensley, 461 U.S. at 434 & n.9). “[T]he amount involved and the results obtained must be addressed in the initial lodestar calculation when determining the reasonable number of hours expended.” Id. (quotation omitted).

2025Based on its consideration of the factors in the second part of the lodestar analysis, the district court may “enhance or decrease the lodestar amount, although ‘many of these 15 factors usually are subsumed within the initial calculation of hours reasonably expended at a reasonable hourly rate.’” Krause, 925 N.W.2d at 33 (quoting Hensley, 461 U.S. at 434 & n.9). “[T]he amount involved and the results obtained must be addressed in the initial lodestar calculation when determining the reasonable number of hours expended.” Id. (quotation omitted).

2019See id. at 711-12 ; Cty. of Dakota v. Cameron , 812 N.W.2d 851 , 865-66 (Minn. App. 2012).

2016Moreover, the United States Supreme Court has stated that in performing a lodestar analysis, “[t]he attorney’s fee provided for in a contingent-fee agreement is not a ceiling .upon the fees recoverable.” Blanchard v. Bergeron, 489 U.S. 87, 96 , 109 S.Ct. 939, 946 , 103 L.Ed.2d 67 (1989) (addressing- district court’s award of attorney fees in case involving claim of. deprivation of civil rights).

2016Moreover, the United States Supreme Court has stated that in performing a lodestar analysis, “[t]he attorney’s fee provided for in a contingent-fee agreement is not a ceiling .upon the fees recoverable.” Blanchard v. Bergeron, 489 U.S. 87, 96 , 109 S.Ct. 939, 946 , 103 L.Ed.2d 67 (1989) (addressing- district court’s award of attorney fees in case involving claim of. deprivation of civil rights).

2014Parsons next argues that the compensation judge erred by failing to consider the size of Braatz’s claim and the fee award under the lodestar analysis we discussed in Green v. BMW of North America, LLC, 826 N.W.2d 530 (Minn. 2013).

2014In the alternative, Parsons argues that even if the employee did not forfeit his right to attorney fees, the compensation judge and the WCCA failed to properly consider the lodestar analysis set forth in Green v. BMW of North America, LLC, 826 N.W.2d 530 (Minn.2013).

2014The supreme court rejected this argument, noting that “the [district] court retained the discretion to evaluate the reasonableness of the award by considering all of the lodestar factors.” Id.

2014Id.

2010The lodestar of our analysis under the Fourth Amendment is “the reasonableness in all the circumstances of the particular governmental invasion of a citizen’s personal security.” Pennsylvania v. Mimms, 434 U.S. 106, 108-09 , 98 S.Ct. 330, 332 , 54 L.Ed.2d 331 (1977) (quotation omitted).

2010The lodestar of our analysis under the Fourth Amendment is “the reasonableness in all the circumstances of the particular governmental invasion of a citizen’s personal security.” Pennsylvania v. Mimms, 434 U.S. 106, 108-09 , 98 S.Ct. 330, 332 , 54 L.Ed.2d 331 (1977) (quotation omitted).

2009Id.