Crowhurst v. Szczucki
- John Koeltl
- 1:16-cv-00182
- U.S. District Court · Southern District of New York
- 9
In Crowhurst v. Szczucki, Judge Koeltl awarded Jennifer Crowhurst $5,403.60 in fees and costs after approving a magistrate judge’s recommendation.
Jennifer Crowhurst received an award of $4,400 in attorney’s fees and $1,003.60 in costs against the Fannie Rebecca Stein Special Needs Trust; the ruling addressed the fees and costs sought for her wage-theft claims.
What happened
Crowhurst v. Szczucki concerned Jennifer Crowhurst’s request for attorney’s fees and costs after resolving her wage-theft claims against the Fannie Rebecca Stein Special Needs Trust under federal and New York wage laws. A magistrate judge recommended $4,400 in fees and $1,003.60 in costs, and Crowhurst objected.
The court found that the lawyers’ billing records were too vague, included work on unrelated claims, and reflected time that was not reasonably necessary. It also agreed that the claims were not unusually complex and that the lawyers’ experience and performance did not support the higher requested rates. The court found the recommended costs reasonable as well.
Judge John G. Koeltl overruled Crowhurst’s objections, adopted the magistrate judge’s recommendation, and granted the motion for attorney’s fees and costs in the amount of $5,403.60.
The detailed version
- Crowhurst v. Szczucki · No. 1:16-cv-00182
- John Koeltl
- Jan. 11, 2020
Background
Jennifer Crowhurst brought multiple claims against the defendants, including medical-malpractice, negligence, and wage-theft claims. The fee request concerned only the wage-theft claims against the Fannie Rebecca Stein Special Needs Trust (the “Stein Trust”), which had been separated from the other claims. A final judgment on those claims totaled $22,527.92, including interest.
Crowhurst requested $93,275 in attorney’s fees. Magistrate Judge Gabriel Gorenstein recommended awarding $4,400 in fees and $1,003.60 in costs. Crowhurst timely objected to the recommended reductions in the number of compensable hours and the lawyers’ hourly rates.
Attorney’s Fees
The court reviewed the challenged portions of the magistrate judge’s recommendation independently and adopted the recommendation. It held that the fee chart could properly be disregarded because it lacked detail, used block billing for lengthy periods, included entries that did not match events in the record, and included work unrelated to the wage claims. The court also agreed that most of the litigation work—including discovery disputes, interrogatories, document requests, and depositions—concerned the unrelated tort claims.
The court further agreed that continued litigation after the Stein Trust’s March 2019 settlement offer was not reasonably necessary. The Trust had offered $22,500 plus legal fees, while Crowhurst’s complaint sought $16,400 on the wage claims. The eventual judgment was $22,527.92. The court found that 20 hours was a reasonable amount of time to include in the fee calculation for work on the wage claims.
For hourly rates, the court considered the claims’ limited complexity, lack of unusual timing demands, the lawyers’ demonstrated experience, and the quality of their work. It approved rates of $225 per hour for two lead attorneys and $175 per hour for an attorney who spent minimal time on the claims. Using those hours and rates, the court upheld the $4,400 fee award.
Costs and Disposition
Crowhurst did not object to the recommended $1,003.60 in costs. The court found that amount reasonable despite the lack of detail for parking, gas, tolls, Westlaw, and travel expenses.
Judge Koeltl overruled Crowhurst’s objections, adopted the magistrate judge’s Report and Recommendation in its entirety, and granted Crowhurst’s motion for attorney’s fees and costs in the amount of $5,403.60. The court directed the Clerk to close the two listed docket entries.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.