Moreno

Facts

Moreno sued the City of Sacramento and several other defendants, alleging that they violated his civil rights by seiz- ing 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, includ- ing 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 investi- gation was unnecessary. The district court also reduced Mil- ler’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 9522 MORENO v. CITY OF SACRAMENTO award was $428,053.00, around 40 percent lower than…