Ingrim v. Oroudjian

It is not an abuse of discretion when a district judge awards attorney fees based on settlement discussions, superfluous work, and the judges own experience of what constitutes reasonable compensation.

Oroudjian owns the building where Ingrim lives. When Ingrim’s rent check was not honored in 2008, Oroudjian filed a detainer action in state court. Ingrim, joined by the Fair Housing Council of San Fernando Valley, filed action in federal court claiming discrimination based on Ingrim’s disability. After Ingrim prevailed in the detainer action, the district court prompted the parties to settle. The case settled after extended negotiations and Ingrim filed for attorney fees in the amount of $88,875.50. The district court awarded $30,485 after finding that some of the hours billed were for unnecessary actions, that Ingram protracted settlement discussions, and after reducing the hourly compensation rate. Ingrim appealed, claiming that the district court should not have considered settlement discussions, reduced the amount of hours billed, or the rate of compensation. The Ninth Circuit joined the Third Circuit in allowing judges to consider actions taken during settlement when awarding attorney fees. The Court also found that it was within the district court judge’s discretion to cut compensation for unnecessary work. Finally, the Court found that Judges may rely on their own experience in considering what a reasonable compensation rate is when awarding attorney fees. AFFIRMED.