Simpson v. Chassen
- Jesse Furman
- 1:25-cv-04004
- U.S. District Court · Southern District of New York
- 3
In Simpson v. Chassen, Judge Furman awarded Chassen $27,271.62 in fees and costs after reducing the requested amount.
Defendant Jared Chassen receives a judgment for $27,271.62 in attorney’s fees and costs; the order also immediately permits enforcement of that judgment.
What happened
In Simpson v. Chassen, the court had previously awarded Defendant Jared Chassen attorney’s fees connected to a request to send the case back to state court. The court ordered Chassen to provide billing records and invited Plaintiff Jeffrey Simpson to respond.
Simpson’s response did not address the requested fees and costs; instead, it repeated his disagreement with the court’s earlier finding that the removal was objectively unreasonable. The court had already denied reconsideration of that finding.
Judge Jesse M. Furman found Chassen’s counsel’s hourly rate reasonable but excluded $33,354 for work on an earlier removed action. He awarded $27,081 in fees and $190.62 in costs, and directed the clerk to enter judgment for Chassen totaling $27,271.62, immediately enforceable.
The detailed version
- Simpson v. Chassen · No. 1:25-cv-04004
- Jesse Furman
- July 30, 2025
Background
On June 27, 2025, the court granted Defendant Jared Chassen’s request for attorney’s fees under 28 U.S.C. § 1447(c), ordered him to submit an accounting supported by contemporaneous billing records and other documentation, and invited Plaintiff Jeffrey Simpson to respond. Chassen then submitted his fee and cost request.
Simpson’s opposition did not address Chassen’s requested fees or costs. Instead, it repeated Simpson’s disagreement with the court’s earlier finding that his removal of the action was objectively unreasonable. The court noted that it had already denied reconsideration of that finding.
Fee Calculation
The court applied the lodestar method, which calculates a presumptively reasonable fee by multiplying a reasonable hourly rate by a reasonable number of hours. The court found that Chassen’s counsel charged a reasonable hourly rate, but concluded that the request improperly included hours billed in a prior removed action in the same district.
The court reduced the claimed attorney’s fees by $33,354, the amount attributed to work on the prior action. That reduction left $27,081 in attorney’s fees. The court also awarded $190.62 in costs.
Ruling
The court awarded Chassen attorney’s fees and costs totaling $27,271.62. It found no reason to delay enforcement of the award and directed the clerk to enter judgment in favor of Chassen for that amount.
Judge Jesse M. Furman signed the memorandum opinion and order on July 30, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.