Central Pension Fund of the International Union of Operating Engineers & Participating Employers v. Ray Haluch Gravel Co., 745 F.3d 1

Central Pension Fund (the Fund) sued Ray Haluch, Inc. to recover unpaid employer contributions under a collective bargaining agreement and ERISA; suit sought nearly $200,000 including claims for unidentified “John Doe” employees.
After a bench trial the district court awarded the Fund $26,897.41 in damages (rejecting the John Doe claims) and later awarded attorneys’ fees and costs after a separate ruling.
The district court calculated a lodestar of $84,656.50 (after reducing claimed hours by one-third), then reduced that lodestar to a final fee award of $18,000 and awarded $16,688.15 in expenses.
The Fund appealed the fee award as too small (arguing the court overemphasized proportionality); Haluch cross-appealed, challenging travel time and travel-expense reimbursement.
The First Circuit reviewed the fee award for abuse of discretion, analyzed lodestar methodology and proportionality, and affirmed the district court’s award and treatment of travel-related claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion by reducing lodestar to $18,000	Fund: Court overemphasized proportionality to damages; fee should be larger	Haluch: (cross-appeal focuses on travel) court’s award otherwise acceptable	Affirmed — court permissibly considered proportionality as one factor and its sizeable reduction was within discretion
Whether proportionality between fees and damages may be used as controlling rule	Fund: proportionality should not be used to limit fees; strict proportionality rejected	Haluch: argues fee should reflect limited damages (supports reduction)	Court: Strict proportionality is not required, but proportionality is a relevant factor and may be weighed alongside lodestar adjustments
Whether unsuccessful claims (e.g., John Doe) justify reducing fees for time spent on those claims	Fund: contends entitlement to fees for work done; seeks broader award	Haluch: work on unsuccessful claims supports reduction	Held: Time spent on unsuccessful/overreaching claims properly considered; reduction permissible under Hensley framework
Whether travel time and travel-related expenses were properly allowed	Haluch: travel time not separately identified/discounted; travel expenses excessive	Fund: travel was necessary; reasonable reimbursement allowed	Held: Travel time and reasonable travel expenses may be reimbursed; district court’s across-the-board reductions and allowance were within wide discretion

Alyeska Pipeline Serv. Co. v. Wilderness Soc’y, 421 U.S. 240 (U.S. 1975) (general rule that parties bear their own fees absent statute/contract)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (lodestar hours: exclude excessive/duplicative time; adjust for success)
Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542 (U.S. 2010) (lodestar approach and its flexibility)
City of Riverside v. Rivera, 477 U.S. 561 (U.S. 1986) (damages amount relevant to fee awards; rejects strict proportionality)
United States v. Metro. Dist. Comm’n, 847 F.2d 12 (1st Cir. 1988) (trial judge’s role and discretion in fee awards)
Coutin v. Young & Rubicam P.R., Inc., 124 F.3d 331 (1st Cir. 1997) (lodestar adjustments and factors)
Gay Officers Action League v. Puerto Rico, 247 F.3d 288 (1st Cir. 2001) (abuse-of-discretion standard for fee awards)
Spooner v. EEN, Inc., 644 F.3d 62 (1st Cir. 2011) (review standard for fee awards)
Hutchinson ex rel. Julien v. Patrick, 636 F.3d 1 (1st Cir. 2011) (attorney travel time may be reimbursed)
Boston & Me. Corp. v. Moore, 776 F.2d 2 (1st Cir. 1985) (reasonable travel costs reimbursable)