problem claim in California

2009“Under Serrano III, a court assessing attorney fees begins with a touchstone or lodestar figure, based on the ‘careful compilation of the time spent and reasonable hourly compensation of each attorney . . . involved in the presentation of the case.’ (Serrano III, supra, 20 Cal.3d at p. 48 .) We expressly approved the use of prevailing hourly rates as a basis for the lodestar, noting that anchoring the calculation of attorney fees to the lodestar adjustment method ‘ “is the only way of approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the ba

1998Moreover, its adoption of the lodestar method of calculating reasonable fees was based on the premise that anchoring the analysis to the lodestar figure “ ‘is the only way of approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.’ ” (Serrano III, supra, 20 Cal.3d at p. 48, fn. 23 , quoting City of Detroit v. Grinnell Corporation (2d Cir. 1974) 495 F.2d 448, 470 .) Thus its pronouncements cannot be read as necessarily limited only to fees awarded under section 1021.5.

2018Anchoring the analysis to this concept is the only way of approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.' " ( Press v. Lucky Stores, Inc. (1983) 34 Cal.3d 311 , 322, 193 Cal.Rptr. 900 , 667 P.2d 704 .) In setting attorney's fees "[t]he basis for the trial court's calculation must be the actual hours counsel has devoted to the case, less those that result from inefficient or duplicative use of time." ( Horsford v. Board of Trustees of California State University (2005) 132 Cal.App.4th 359 , 395, 33 Cal.Rptr.3d 644

2018Anchoring the analysis to this concept is the only way of approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.' " ( Press v. Lucky Stores, Inc. (1983) 34 Cal.3d 311 , 322, 193 Cal.Rptr. 900 , 667 P.2d 704 .) In setting attorney's fees "[t]he basis for the trial court's calculation must be the actual hours counsel has devoted to the case, less those that result from inefficient or duplicative use of time." ( Horsford v. Board of Trustees of California State University (2005) 132 Cal.App.4th 359 , 395, 33 Cal.Rptr.3d 644

2026Anchoring the analysis to this concept is the only way of approaching the problem that can claim objectivity . . . .’”” (Roe v. Halbig (2018) 29 Cal.App.5th 286, 311 (Roe).) Thus, “[i]n setting attorney’s fees ‘[t]he basis for the trial court's calculation must be the actual hours counsel has devoted to the case, less those that result from inefficient or duplicative use of time.’” (Ibid.) Although a trial court is not required to issue a statement of decision regarding a fee award or to identify each charge it finds unreasonable, it must articulate—at least in general terms—its reasons for si

2026(Snoeck v. ExakTime Innovations, Inc. (2023) 96 Cal.App.5th 908 , 921.) That is, a court presented with a voluminous fee request may “‘“make across-the-board percentage cuts either in the number of hours claimed or in the final lodestar figure,”’” but it “must clearly explain its reasons for choosing the particular [reduction] that it chose; otherwise, the reviewing court is unable to determine that the court had valid, specific reasons for its across-the-board percentage reduction.” (Warren v. Kia Motors America, Inc. (2018) 30 Cal.App.5th 24, 41 (Warren).) Where no statement of decision is r

2016(See People v. Holford (2012) 203 Cal.App.4th 155, 174 [“nature of discretion requires that the court’s decision be an informed one”].) But it is a problem defense counsel could have remedied.

2016In effect, the court determines, retrospectively, whether the litigation involved a contingent risk or required extraordinary legal skill justifying augmentation of the unadorned lodestar in order to approximate the fair market rate for such services.” (Id. at p. 1132.) “[Anchoring the calculation of attorney fees to the lodestar adjustment method ‘ “is the only way of *272 approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.” ’ ” (Ibid.) “When using the lodestar method to calculate attorney fees ... , the ultimate goal

2016In effect, the court determines, retrospectively, whether the litigation involved a contingent risk or required extraordinary legal skill justifying augmentation of the unadorned lodestar in order to approximate the fair market rate for such services.” (Id. at p. 1132.) “[Anchoring the calculation of attorney fees to the lodestar adjustment method ‘ “is the only way of *272 approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.” ’ ” (Ibid.) “When using the lodestar method to calculate attorney fees ... , the ultimate goal

2015(Serrano [v. Priest (1977)] 20 Cal.3d [25], 49 [(Serrano III)].)” (Ketchum, at p. 1134.) The court reaffirmed this approach yet again in Graham v. DaimlerChrysler Corp. (2004) 34 Cal.4th 553, 579 [“ ‘anchoring the calculation of attorney fees to the lodestar adjustment method “ ‘is the only way of approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.’ ” [Citation.]’ ”) Use of the lodestar does not, however, mean a party seeking attorneys’ fees is “necessarily entitled to compensation for the value of attorney services ac

2015(Serrano [v. Priest (1977)] 20 Cal.3d [25], 49 [(Serrano III)].)” (Ketchum, at p. 1134.) The court reaffirmed this approach yet again in Graham v. DaimlerChrysler Corp. (2004) 34 Cal.4th 553, 579 [“ ‘anchoring the calculation of attorney fees to the lodestar adjustment method “ ‘is the only way of approaching the problem that can claim objectivity, a claim which is obviously vital to the prestige of the bar and the courts.’ ” [Citation.]’ ”) Use of the lodestar does not, however, mean a party seeking attorneys’ fees is “necessarily entitled to compensation for the value of attorney services ac

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend

2014(Christian Research Institute v. Alnor (2008) 165 Cal.App.4th 1315, 1320 [ 81 Cal.Rptr.3d 866 ].) “‘[T]he court may require [a] defendant[] to produce records sufficient to provide “ ‘a proper basis for determining how much time was spent on particular claims.’ ” [Citation.] The court also may properly reduce compensation on account of any failure to maintain appropriate time records. [Citation.]’ [Citation.] The evidence should allow the court to consider whether the case was overstaffed, *487 how much time the attorneys spent on particular claims, and whether the hours were reasonably expend