Hunt v. Zuffa, LLC
2:17-cv-00085
| D. Nev. | Mar 26, 2024Background
- Mark Hunt sued Brock Lesnar, Dana White, and Zuffa, LLC (UFC) after losing a 2016 UFC bout, alleging Lesnar's use of performance-enhancing drugs and UFC's complicity.
- The initial lawsuit was dismissed and UFC was awarded attorneys’ fees under a 2016 contract specifying the prevailing party could recover such fees.
- The Ninth Circuit revived some of Hunt’s claims (fraud, battery, aiding-and-abetting battery, civil conspiracy) on appeal, allowing further discovery.
- After discovery, the court again granted summary judgment for UFC and Lesnar, finding insufficient evidence to support Hunt’s claims.
- UFC moved for additional attorneys’ fees and costs for litigation after remand, supported by the same contractual provision; Hunt did not oppose the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Contractual right to attorneys’ fees | Claims arise from wrongdoing, not contract | Litigation concerns agreement; contract allows fee award to prevailing party | UFC entitled to attorneys’ fees under contract |
| Reasonableness of fee request | (No argument; Hunt did not respond) | Fees are reasonable, supported by documentation, and calculated per local standards | Fee request reasonable and proper |
| Award of litigation costs | (No argument; Hunt did not respond) | Contract allows costs broader than federal baseline; seeks costs under Nevada law | Only certain costs reasonable/authorized; data-hosting and excess expert fees reduced |
| Amount of recoverable expert/data fees | (No argument; Hunt did not respond) | Seeks full itemized costs for experts and data | Reduces to statutory limits; awards only $15,000/expert, disallows unjustified data costs |
Key Cases Cited
- Alyeska Pipeline Serv. Co. v. Wilderness Soc’y, 421 U.S. 240 (Supreme Court confirmed prevailing party can recover attorneys’ fees only if authorized by contract or statute.)
- MRO Commc’ns, Inc. v. AT&T, 197 F.3d 1276 (9th Cir. established fee awards require an independent basis such as contract or statute.)
- Schouweiler v. Yancey Co., 712 P.2d 786 (Nevada law recognizes contractual fee-shifting provisions as authority for attorneys’ fees.)
- Brunzell v. Golden Gate Nat’l Bank, 455 P.2d 31 (Nevada Supreme Court set out factors for evaluating reasonableness of attorneys’ fees.)