City of Little Rock v. Ladonna Nelson, as Parent and Next Friend of Ricky Nelson, Individually, and on Behalf of Others Similarly Situated, 592 S.W.3d 666

On May 12, 2014, LaDonna Nelson filed an illegal-exaction and Arkansas Civil Rights Act class action challenging installment fees charged in Little Rock traffic court.
The circuit court certified a class of defendants who paid installment fees at least thirty days early; the City moved to dismiss and opposed certification.
After a two-day trial in August 2018, a jury found the City violated the Arkansas Civil Rights Act and the court entered an order awarding $8,670 in damages and directing refunds to certain class members.
Nelson moved for attorneys’ fees, costs, and a $10,000 enhancement for class-representative services, seeking $397,542.42 total.
The circuit court held a hearing, awarded $225,000 in attorneys’ fees to Nelson’s counsel and $10,000 to Nelson, and the City appealed only the fee awards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court abused its discretion in awarding $225,000 in attorneys’ fees	Nelson argued the trial court correctly applied the Chrisco factors, no proportionality rule limits fee awards, counsel faced contingent risk and incurred expenses, and produced continued work after judgment	City argued the requested fee was "grossly disproportionate" to the $8,670 damages and excessive under Chrisco	Affirmed — court found trial court properly considered Chrisco factors, reduced request to $225,000, and did not abuse discretion
Whether the $10,000 enhancement to the class representative was unreasonable	Nelson argued an enhancement was appropriate for services to the class	City argued the enhancement was unreasonable and should be reduced but offered no legal authority or developed argument	Affirmed — City failed to support the challenge with authority; appellate court refused to consider unsupported argument

Chrisco v. Sun Indus., 304 Ark. 227 (1990) (factors to consider in awarding attorneys’ fees)
Furman v. Second Injury Fund, 336 Ark. 10 (1999) (attorneys’ fees require statutory authorization)
Lake View Sch. Dist. No. 25 v. Huckabee, 340 Ark. 481 (2000) (Arkansas follows the American rule on attorneys’ fees)
Love v. Smackover Sch. Dist., 329 Ark. 4 (1997) (same; fees are not presumptive without statute)
South Beach Beverage Co. v. Harris Brands, 355 Ark. 347 (2003) (no fixed formula for reasonable attorneys’ fees)
Phi Kappa Tau Hous. Corp. v. Wengert, 350 Ark. 335 (2002) (trial court has superior perspective on fee-factor assessment; abuse-of-discretion review)
Williams v. Brushy Island Pub. Water Auth., 368 Ark. 219 (2006) (appellate courts will not consider arguments unsupported by authority)