Greenlight Systems, LLC v. Breckenfelder
- Edward Chen
- 3:19-cv-06658
- U.S. District Court · Northern District of California
- 5
In Greenlight Systems v. Breckenfelder, Judge Chen granted Breckenfelder’s fee motion and awarded $44,091.65 in statutory attorneys’ fees against the counterdefendants.
Erik Breckenfelder received a $44,091.65 statutory attorneys’ fee award. Greenlight Systems, LLC, Orbital Asset Holdings, Inc., and Andrew D.B. Rowen were ordered to be jointly and severally liable for that amount, which was added to the judgment.
What happened
In Greenlight Systems, LLC v. Breckenfelder, Greenlight Systems, Orbital Asset Holdings, and Andrew D.B. Rowen were responsible for counterclaims brought by Erik Breckenfelder after the court dismissed their complaint and entered default on his counterclaims. The court had entered judgment for Breckenfelder on his contract, employment, fraud, conversion, and wage-related claims.
Breckenfelder asked for attorneys’ fees for his successful wage-and-hour claims under federal and California law. He proposed using one-third of fees incurred before May 28, 2020, and one-half of fees incurred afterward, because his recoverable claims represented those portions of the claims pending during each period. The court found that method and the submitted hourly rates and time records reasonable.
Judge Edward M. Chen granted the motion and determined that Breckenfelder was entitled to $87,575.40 in fees, including $2,170 for preparing the fee motion. After subtracting previously awarded sanctions, the court ordered $44,091.65 in statutory attorneys’ fees added to the judgment, with the counterdefendants jointly and severally liable.
The detailed version
- Greenlight Systems, LLC v. Breckenfelder · No. 3:19-cv-06658
- Edward Chen
- Oct. 12, 2021
Background
Greenlight Systems, LLC and Orbital Asset Holdings, Inc. sued Erik Breckenfelder for fraud and breach of contract related to an employment agreement. The court dismissed that complaint, entered default on Breckenfelder’s counterclaims against Greenlight, Orbital, and Andrew D.B. Rowen, and later entered default judgment on Breckenfelder’s contract and employment counterclaims in the amount of $691,384.30.
Breckenfelder’s counterclaim included four wage-and-hour claims for which federal or California law permits a prevailing employee to recover reasonable attorneys’ fees. The court previously found in his favor on those claims, including claims involving unpaid minimum wages, itemized wage statements, payroll records, and waiting-time penalties. Breckenfelder then filed an unopposed motion seeking fees incurred in pursuing those claims.
Entitlement to Fees
The court held that its prior default judgment established Breckenfelder’s entitlement to reasonable attorneys’ fees and costs on the wage-and-hour claims. The court relied on federal and California statutes providing for fee recovery on successful minimum-wage, wage-statement, and waiting-time claims.
Calculation
The court applied the lodestar method, which calculates reasonable fees by multiplying a reasonable hourly rate by the number of hours reasonably spent. Breckenfelder did not seek fees for the counterdefendants’ claims or for his fraud and conversion claims. Because the counterdefendants’ failure to participate in discovery affected the litigation as a whole, he proposed allocating fees proportionally among the claims.
The court approved that allocation:
- One-third of $83,025.30 for work before May 28, 2020: $27,675.10. - One-half of $115,460.59 for work after May 28, 2020: $57,730.30. - Fees for preparing the fee motion: $2,170.
These amounts totaled $87,575.40. The court then subtracted previously awarded sanctions and ordered $44,091.65 in statutory attorneys’ fees added to the final judgment.
Disposition
Judge Edward M. Chen granted Breckenfelder’s motion for attorneys’ fees. The court awarded $44,091.65 against Greenlight, Orbital, and Rowen, jointly and severally, and ordered that amount added to the judgment. The order disposed of Docket No. 116.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.