HUFF v. DOHRN TRANSFER COMPANY, LLC
1:24-cv-02063
| S.D. Ind. | Jul 21, 2025Background
- This case concerns Dohrn Transfer Company, LLC’s motion for attorney’s fees after prevailing on a motion to compel discovery against plaintiff Meosha Huff.
- The dispute arose when Huff failed to provide adequate discovery responses; after court intervention and guidance, the defendant was authorized to file a formal motion to compel.
- The court granted the motion to compel, and Dohrn subsequently moved for reimbursement of attorney's fees and costs relating to the discovery dispute.
- Plaintiff challenged both the reasonableness of the hourly rates and the number of hours claimed by the defendant’s counsel.
- The court evaluated evidence concerning market rates, billing practices, and specific time entries, and heard argument regarding alleged duplicative and unnecessary work.
- The ruling ordered plaintiff’s counsel—not the plaintiff—to pay $13,051.50 in fees within 14 days due to the conduct that necessitated the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonableness of hourly rate | Defendant failed to provide adequate proof of market rate; affidavits were self-serving | Rates actually billed and paid by client are presumptively reasonable; supplemental declaration filed | Rates are reasonable; presumption not rebutted |
| Overall hours expended | Too many hours billed, including block-billing and redundant work; work on similar issues in prior cases | Hours were reasonable for quality and complexity of submissions | Hours reasonable, objections meritless |
| Certain time entries (e.g., background, exhibits, certifications) | Specific entries (like background, compiling exhibits, certification letter) were excessive or duplicative | Time spent was necessary and submissions aided court understanding | Entries reasonable; no reduction warranted |
| Attendance of two attorneys at hearing | Only one lawyer argued; billing by both was excessive | Standard for both senior/junior attorneys to attend; not unusual or unreasonable | Both attending reasonable; objection overruled |
Key Cases Cited
- Houston v. C.G. Sec. Servs., Inc., 820 F.3d 855 (7th Cir. 2016) (lodestar method is starting point for fee petitions)
- Stark v. PPM Am., Inc., 354 F.3d 666 (7th Cir. 2004) (best evidence of reasonableness is amount actually paid by client)
- Cintas Corp. v. Perry, 517 F.3d 459 (7th Cir. 2008) (detailed client billing is satisfactory for fee petitions)
- Gautreaux v. Chicago Hous. Auth., 491 F.3d 649 (7th Cir. 2007) (district courts have wide discretion assessing fee reasonableness)
- Fox v. Vice, 563 U.S. 826 (2011) (fee-shifting requires “rough justice,” not auditing perfection)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (fees determinations should not result in second major litigation)