Guardant Health, Inc. v. Natera, Inc.
3:21-cv-04062
| N.D. Cal. | Jul 9, 2025Background
- Guardant Health, Inc. sought sanctions against Natera, Inc. for its counsel’s (Quinn Emanuel) deliberate misrepresentations to the court regarding discovery related to the COBRA study.
- The court had earlier found Natera’s counsel acted in bad faith by making false statements about Dr. Hochster’s communications and access to COBRA study results, prompting trial delay and reopening of discovery.
- Guardant requested nearly $3 million in attorneys’ fees and costs, as well as punitive sanctions and referral of attorneys to the State Bar.
- Natera opposed, asserting its counsel acted in good faith and that further sanctions would be excessive, especially after an unfavorable jury verdict.
- The court previously granted evidentiary sanctions, deferred monetary sanctions, and requested supplemental briefing on individual attorney responsibility and monetary amounts.
- The present order grants Guardant’s request for compensatory attorneys’ fees, defers the allocation and punitive sanction questions, and appoints a special master to resolve them.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether further monetary sanctions are appropriate for COBRA misconduct | Natera's counsel's misconduct caused significant costs and delay; full fees warranted | Sanctions already sufficient; further award is a “windfall”; counsel acted in good faith | Further compensatory sanctions granted for fees and costs caused by misconduct |
| Allocation of responsibility for sanctions | Quinn Emanuel attorneys should be sanctioned; court should decide individual liability | Fee claims should be limited, no personal attorney sanctions | Apportionment/individual liability deferred to special master |
| Appropriateness of punitive sanctions and Bar referral | Punitive fines and State Bar referral justified due to egregious conduct | No punitive sanctions; counsel acted in good faith | Issue of punitive sanctions and referral deferred to special master |
| Reasonableness of attorneys’ fees claimed under “but-for” test | Full claimed fees reasonably incurred due to misconduct, as shown in detailed records | Fees should be much narrower, related only to specific enforcement actions | Full amount of claimed fees ($2,985,909.63) granted, plus further motion costs |
Key Cases Cited
- Am. Unites for Kids v. Rousseau, 985 F.3d 1075 (9th Cir. 2021) (clarifies standards for compensatory versus punitive sanctions and "but-for" causation)
- Goodyear Tire & Rubber Co. v. Haeger, 581 U.S. 101 (2017) (discusses necessity of “but-for” causation standard for fee awards in sanctions)
- In re Yagman, 796 F.2d 1165 (9th Cir. 1986) (addressing court’s flexibility in calculating sanctions awards)
- Gates v. Deukmejian, 987 F.2d 1392 (9th Cir. 1992) (outlines burden of proof for reasonableness of fee requests)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (advises courts to exclude excessive or unnecessary hours from fee awards)