Caldwell v. SEYCHELLES LIMITED, LLC
0:23-cv-61267
S.D. Fla.Aug 16, 2024Background
- Plaintiffs Sandra Caldwell and Nancy Newbold sued Seychelles Limited, LLC (the yacht owner) and Tammy Fisher (the charterer) after sustaining injuries on a yacht tender.
- Tammy Fisher (Defendant) entered a “Recreational Bareboat Charter Agreement” with Seychelles Limited, which included an attorneys’ fees provision for prevailing parties.
- Seychelles moved to dismiss all claims against it and argued non-liability under the Charter Agreement.
- Judge Williams granted Seychelles’ motions to dismiss with prejudice, removing Seychelles from the case.
- Seychelles then sought $113,502.57 in attorney’s fees and costs from Fisher under the Charter Agreement.
- Magistrate Judge Augustin-Birch evaluated the fee claim, applying reductions based on reasonableness and billing deficiencies.
Issues
| Issue | Fisher's Argument | Seychelles' Argument | Held |
|---|---|---|---|
| Entitlement to attorneys’ fees under contract | Did not dispute Seychelles’ right to fees per the contract | Sought to enforce Charter Agreement’s fee provision | Seychelles entitled to reasonable fees and costs under contract |
| Allocation of fees (Fisher’s vs. Plaintiffs’ claims) | Seychelles should not recover fees for unrelated work on Plaintiffs’ claims | All work overlapped; no clear division needed | Only fees relating to Fisher’s cross-claims recoverable; reduction applied |
| Reasonable hourly rates and hours expended | Challenged total as excessive but not rates individually | Provided limited external support for rates | Court reduced certain rates, disallowed some hours for vagueness, block billing, and clerical tasks |
| Recovery of costs | No specific objection | Costs recoverable under contract | Court awarded $998.47 in costs as supported and permitted |
Key Cases Cited
- Norman v. Hous. Auth. of City of Montgomery, 836 F.2d 1292 (11th Cir. 1988) (establishing lodestar method for calculating reasonable attorney's fees)
- Blum v. Stenson, 465 U.S. 886 (1984) (burden on fee applicant to justify reasonableness of requested rates)
- Loranger v. Stierheim, 10 F.3d 776 (11th Cir. 1994) (courts as experts on reasonable hourly rates)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (requirement for sufficient detail in billing records)
- Johnson v. Univ. Coll. of Univ. of Ala. in Birmingham, 706 F.2d 1205 (11th Cir. 1983) (distinct contributions requirement for multiple attorneys)