Padgett v. City of Monte Sereno
- Edward Davila
- 5:04-cv-03946
- U.S. District Court · Northern District of California
- 4
In Padgett v. City of Monte Sereno, Judge Davila granted Wright’s motion, ruling interest on renewed fees accrues from March 2015.
A. Curtis Wright and Bustamante & Gagliasso were directly affected: the renewed judgment’s interest must be calculated from March 2015 rather than 2010.
What happened
In Padgett v. City of Monte Sereno, Joseph Padgett won $10,001 after a jury trial on his civil-rights claims. The court later awarded attorneys’ fees, but an appeals court sent the fee award back for further explanation.
After the court awarded fees again in March 2015, Bustamante & Gagliasso sought to renew a judgment for $393,468.29. A. Curtis Wright argued that the renewed judgment included too much interest because interest should begin in March 2015, not when the original fee award was entered in 2010.
The court agreed with Wright and granted his motion to alter Bustamante’s application for renewal of judgment. Judge Edward J. Davila ruled that interest must accrue from the court’s March 2015 fee order.
The detailed version
- Padgett v. City of Monte Sereno · No. 5:04-cv-03946
- Edward Davila
- May 13, 2020
Background
Joseph Padgett sued eight defendants in 2004 for alleged civil-rights violations. After a jury trial, Padgett received $1 in nominal damages and $200,000 in punitive damages. The court reduced the punitive-damages award to $10,000, resulting in a total damages award of $10,001.
In 2010, Judge Ware awarded Padgett $500,000 in attorneys’ fees under 42 U.S.C. § 1988. The Ninth Circuit vacated and sent back that award because the order did not explain how the fees were calculated. On remand, in March 2015, the court awarded the Kallis and Bustamante law firms $471,056.64 and $100,000, respectively, in attorneys’ fees.
The Ninth Circuit later vacated the 2015 fee award because attorneys’ fees generally belong to the plaintiff unless a contract or attorney lien provides otherwise. On October 7, 2019, the court reinstated its 2015 award after finding that the parties’ fee agreement directed the fees and litigation costs to Bustamante. Bustamante then sought renewal of a judgment totaling $393,468.29, and the clerk’s office granted that request on January 22, 2020.
Dispute over interest
Defendant A. Curtis Wright moved to vacate or modify Bustamante’s proposed renewed judgment, arguing that it claimed an inflated amount of post-judgment interest. Bustamante argued that interest should run from June 9, 2010, when Judge Ware originally awarded fees and costs. Wright argued that interest should begin on March 31, 2015, when the court awarded fees and costs after the Ninth Circuit’s remand.
The court applied 28 U.S.C. § 1961 and related Ninth Circuit authority. Those rules generally require interest on money judgments and provide that interest begins when the amount awarded was supported by the evidence and meaningfully determined. Because Judge Ware had not adequately explained the 2010 award and the court changed the amount after analyzing the relevant factors on remand, the court held that the fees had not been meaningfully determined in 2010.
Ruling
The court granted Wright’s motion to alter Bustamante’s application for renewal of judgment. It ordered that interest accrue from the court’s March 2015 order granting attorneys’ fees and costs, rather than from the original 2010 fee award. Judge Edward J. Davila signed the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.