Hateley v. Ford Motor Company

Background

Jeffrey Hateley brought claims against Ford Motor Company for breach of warranty under California’s Song-Beverly Act. The case settled in September 2023 after Hateley accepted Ford’s offer under Rule 68, a federal procedure allowing a party to make a formal settlement offer. The offer left attorneys’ fees and costs for the court to determine, while treating Hateley, in essence, as the prevailing party for that issue.

The Song-Beverly Act provides that a prevailing buyer may recover reasonably incurred costs and attorneys’ fees. Hateley requested $42,900.50 in attorneys’ fees and $5,756.47 in costs and expenses. Ford did not challenge the requested costs and argued that the fee award should be limited to $15,310.00.

Court’s Analysis

The court considered the attorneys’ hourly rates and the number of hours claimed. Hateley submitted evidence supporting the hourly rates, including a fee survey and decisions from other federal and state courts. The court found that most of the hours were reasonable, but determined that some hours involved administrative tasks or were excessive for the work performed.

The court also found that using five timekeepers was unusual for a relatively straightforward case and had caused some inefficiencies. It therefore reduced the requested fees by 10 percent. The court separately found the requested costs and expenses reasonable.

Ruling

Judge Edward Chen granted Hateley’s motion for attorneys’ fees and costs. The court awarded $38,610.45 in attorneys’ fees and $5,756.47 in costs and expenses, for a total award of $44,366.92. The order disposed of Docket No. 19.