Lenk v. Monolithic Power Systems, Inc.
- Beth Freeman
- 5:20-cv-08094
- U.S. District Court · Northern District of California
- 1
Lenk v. Monolithic Power Systems: Judge Freeman denied Lenk’s motion to alter or amend an attorneys’ fee judgment.
Kenneth Lawrence Lenk and Monolithic Power Systems, Inc.; the ruling left in place the earlier order that granted in part and denied in part the defendant’s motion for prevailing-party attorneys’ fees.
What happened
In Lenk v. Monolithic Power Systems, Inc., Kenneth Lawrence Lenk asked the court to change an earlier ruling about the defendant’s request for attorneys’ fees. That earlier ruling granted the fee request in part and denied it in part.
The court considered Lenk’s motion under Rule 59(e), which permits a party to ask the court to change or amend a judgment within 28 days. The court explained that relief generally requires a serious legal or factual error, new evidence, a serious unfairness, or a change in controlling law.
The court found that Lenk had not identified any of those grounds and denied his motion. Judge Beth Labson Freeman issued the order.
The detailed version
- Lenk v. Monolithic Power Systems, Inc. · No. 5:20-cv-08094
- Beth Freeman
- Apr. 18, 2022
Background
Kenneth Lawrence Lenk moved under Federal Rule of Civil Procedure 59(e) to alter or amend the judgment. His motion sought relief from the court’s earlier order that granted in part and denied in part Monolithic Power Systems, Inc.’s motion for prevailing-party attorneys’ fees. The court decided the motion without requesting a response from the defendant and without oral argument.
Legal standard
Rule 59(e) allows a party to seek a change to a judgment within 28 days after the judgment is entered. The court noted that some district courts in the Ninth Circuit have held that Rule 59(e) cannot be used to challenge an attorneys’ fee award. The court nevertheless assumed, for purposes of its decision, that Lenk’s motion could be brought under Rule 59(e).
To obtain relief, Lenk needed to identify a manifest error of law or fact, newly discovered evidence, a manifest injustice, or an intervening change in controlling law. The court found that he had not identified any qualifying ground for relief.
Ruling
The court denied Lenk’s Rule 59(e) motion. Judge Beth Labson Freeman signed the order on April 18, 2022.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.