Goff v. Ruff Neon and Lighting Maintenance, Inc., 1:16-cv-00194

Plaintiff Kevin Goff sued under the FLSA for unpaid overtime; parties settled and reserved attorney's fees for the court to decide.
Plaintiff sought $37,790.00 in fees plus $472.88 in costs; three attorneys billed (hours and rates detailed).
Settlement agreement and 29 U.S.C. § 216(b) entitled plaintiff to reasonable attorney's fees and costs.
Defendants argued the claim was straightforward, recovery small relative to demand, discovery and motion practice were minimal, and three attorneys were unnecessary.
Court applied the lodestar method, evaluated prevailing market rates for Northeast Ohio, found certain hourly rates reasonable but concluded hours were excessive given the case facts.
Court reduced fees by 40%, awarded $21,489.00 in attorney fees and $472.88 in costs; denied plaintiff's motion to strike portions of defendant's opposition (but ignored settlement negotiation content per Rule 408).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to fees	Goff is prevailing party under FLSA and settlement/agreement requires defendants to pay reasonable fees	Defendants did not dispute entitlement	Court: Plaintiff entitled to reasonable fees under 29 U.S.C. § 216(b) and the settlement agreement
Proper method to calculate fees	Lodestar (hours × reasonable rate) should govern	Lodestar governs; reasonableness of hours and rates subject to challenge	Court: Apply lodestar using prevailing market (N. Ohio) rates
Reasonableness of hourly rates	Proposed rates ($275–$300 for experienced counsel; lower for junior) are consistent with market and cited authorities	Challenged only the amount, not entitlement to fees; argued fee should reflect simple nature/recovery	Court: Adopted $275/hr for Clifford Bendau and James Simon; $125/$175 for Christopher Bendau (clerk/attorney) as reasonable for this district
Reasonableness of hours / total fee award	Submitted detailed hours for three attorneys and also sought additional fees for fee-reply work	Argued case was routine, required minimal work, three attorneys and claimed hours were excessive; recovery small relative to fees requested	Court: Reduced lodestar by 40% as excessive given single-claim, minimal discovery, boilerplate filings; awarded $21,489.00 in fees and costs $472.88

Blanchard v. Bergeron, 489 U.S. 87 (1989) (endorses lodestar methodology)
Pennsylvania v. Delaware Valley Citizens' Council for Clean Air, 478 U.S. 546 (1986) (lodestar presumed reasonable)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (hours reasonably expended × reasonable rate; reduce when limited success)
Blum v. Stenson, 465 U.S. 886 (1984) (reasonable hourly rate measured by prevailing market)
Gonter v. Hunt Valve Co., Inc., 510 F.3d 610 (6th Cir.) (prevailing market = venue of the court of record)
Lavin v. Husted, 764 F.3d 646 (6th Cir.) (reasonable FLSA fees: adequate to attract competent counsel without producing windfall)
Imwalle v. Reliance Med. Prods., Inc., 515 F.3d 531 (6th Cir.) (focus on overall relief when claims share common facts)
Waldo v. Consumers Energy Co., 726 F.3d 802 (6th Cir.) (degree of success is critical in fee reasonableness analysis)