Moreno

We consider various issues pertaining to the district court’s award of attorneys’ fees under 42 U.S.C. § 1988 .

Facts

Moreno sued the City of Sacramento and several other defendants, alleging that they violated his civil rights by seizing and destroying his property without due process. After lengthy pre-trial proceedings and a previous appeal, a jury awarded Moreno $717,000 in compensatory and punitive damages. Moreno’s principal trial counsel, Andrea Miller, sought an award of attorneys’ fees under 42 U.S.C. § 1988 . Miller requested $704,858.07 for herself and her staff, including compensation for 1,973.6 hours of her own time, at a rate of $300 per hour. This request excluded around 9 percent of the total hours actually spent on the case.

The district court reduced the hours further, concluding that around a quarter to a third of the time spent on research, appeal and trial preparation and half the time spent on investigation was unnecessary. The district court also reduced Miller’s hourly rate to that of a paralegal for the time she spent summarizing depositions. Finally, the district court reduced Miller’s hourly rate from $300 to $250 an hour. The resulting award was…