Carter v. Caleb Brett LLC

When a district court significantly reduces a fee award, it must explain with specificity its reasons for the reduction.

Rick Carter petitioned the district court for attorneys' fees in the amount of $22,585. However, the court only awarded him $14,268.50 in attorneys' fees and costs. Carter appealed the district court's award of attorneys' fees, arguing that the district court did not provide a sufficient explanation for the reduction. When a district court awards attorneys' fees, it must provide a clear, concise explanation of why it is rewarding a specific amount. Kerr v. Screen Extras Guild, Inc. provides twelve factors that courts consider when determining attorneys' fees. In the district court's rationale for reducing Carter's fees by 27%, it mentioned two of the Kerr factors that the court considered, but the court did not sufficiently explain how those factors affected the fee award. Since the district court failed to provide specific reasons explaining its rationale for the reduction of Carter's award, the Ninth Circuit vacated and remanded the case with instructions for the district court to explain with specificity the reasons for the reduction in order for the appellate court to review the reasonableness of the fee award. VACATED AND REMANDED.