Hernandez v. Spring Charter Inc.

Background

Gerardo Hernandez sued Spring Charter Inc. and Satnam LLC after encountering accessibility issues at Valley Market & Gas in March 2019. He alleged violations of the Americans with Disabilities Act and California’s Unruh Civil Rights Act. The parties later agreed to dismiss the claims, leaving the amount of attorney’s fees and costs for the court to decide. The court had dismissed Hernandez’s claims with prejudice on December 11, 2019, while retaining jurisdiction over the fee dispute.

Hernandez sought attorney’s fees for attorney Tanya E. Moore and paralegals Whitney Law and David Guthrie. He requested $32,842 in fees and $3,300.48 in litigation expenses and costs. The defendants challenged the requested hourly rates and argued that many of the claimed hours were excessive, duplicative, clerical, or otherwise not compensable.

Prevailing-Party Status

The court held that Hernandez was the prevailing party for purposes of the Americans with Disabilities Act. Although the case ended through settlement rather than a trial, the settlement required architectural changes to the property and payments to Hernandez. The court concluded that these requirements materially changed the parties’ legal relationship and directly benefited Hernandez.

Attorney’s Fees

The court approved the requested hourly rates: $475 for Moore, $150 for Law, and $120 for Guthrie.

The court reduced the requested hours because the case settled early, involved no pre-dismissal motion practice, included no court appearances, and involved minimal discovery. It reduced Moore’s hours by 12 and Law’s hours by 9 based on the overall amount of time claimed and the nature of the case.

The court also made additional reductions for time spent preparing the fee motion and reply, duplicate billing entries, reviewing short and non-substantive court filings, and clerical tasks. It did not reduce the hours for complaint preparation, the joint site inspection, or the meet-and-confer work.

After these deductions, the court calculated the lodestar—the presumptively reasonable fee based on reasonable hours multiplied by reasonable hourly rates—as follows:

- Moore: 29.7 hours at $475 per hour, totaling $14,107.50. - Law: 17.9 hours at $150 per hour, totaling $2,685. - Guthrie: 1.2 hours at $120 per hour, totaling $144. - Total attorney’s fees: $16,936.50.

The court declined to apply any additional downward adjustment based on the defendants’ arguments about the case’s simplicity, Hernandez’s prior disability-access litigation, or the amount of damages. The court found that Hernandez obtained all the injunctive relief he sought and that the requested statutory damages represented the full amount available under the California statute identified in the opinion.

Costs and Disposition

The court approved all $3,300.48 in requested litigation expenses and costs, consisting of the filing fee, service costs, site-inspection expenses, and pre-filing investigation fees. The court rejected the argument that Hernandez should not recover the full site-inspection expense because he chose a consultant located farther from the property.

Judge Thomas S. Hixson granted in part and denied in part Hernandez’s motion for attorney’s fees. The court awarded Hernandez $16,936.50 in attorney’s fees and $3,300.48 in litigation expenses and costs, for a total award of $20,236.98.