Antolini v. McCloskey

Background

On June 22, 2022, Magistrate Judge Stewart Aaron ordered plaintiff’s counsel, attorney Stuart H. Finkelstein, to pay Defendants $14,180 in attorneys’ fees within 14 days. The fees concerned sanctions briefing. Finkelstein filed objections under Federal Rule of Civil Procedure 72(a) and 28 U.S.C. § 636(b)(1), asking the district court to vacate the fee order and temporarily pause it while the objections were considered.

Court’s analysis

For a magistrate judge’s order on a nondispositive matter, a district judge may change or set aside the order only if it is clearly erroneous or contrary to law. The court explained that this is a highly deferential standard and that the objecting party bears a heavy burden.

Finkelstein argued that the fee order failed to account for his December 21, 2021 opposition letter. The court rejected that argument because the order expressly cited the letter in its summary of the dispute. Finkelstein also argued that he should not have to pay attorneys’ fees under controlling case law or Rule 37. The court found that these arguments improperly sought to reargue the merits of an earlier monetary-sanctions ruling that the district court had already adopted in full.

The court concluded that Magistrate Judge Aaron correctly applied the relevant legal standard and reasonably reduced the requested fees to account for excessive work by Defendants’ counsel. It found nothing in the fee order that was clearly erroneous or contrary to law.

Ruling

Judge Daniels overruled Finkelstein’s Rule 72(a) objections and denied his request for a stay. The court adopted Magistrate Judge Aaron’s order in its entirety and ordered Finkelstein to pay Defendants $14,180 for attorneys’ fees incurred in connection with the sanctions briefing.