In the Matter of the Attorney's Fees and Costs In the Termination of Parental Rights To: Kmo, Dmo, Cmo, Ako, Dko, Mto, Abo, Eeo, and Jbo, Minor Children, Donald Lee Tolin, Attorney for Hjo, Natural Mother v. State of Wyoming, Department of Family Services, 309 P.3d 827

Mother’s parental rights were terminated; this appeal concerns the district court’s post-judgment award of counsel fees to mother’s appointed appellate attorney, Donald Tolin.
Tolin sought $121,530.00 in attorney’s fees and $3,468.84 in costs, billing at $100/hour with a threatened increase to $200/hour if the Department of Family Services (DFS) contested the bill.
The district court reduced the award to $25,000.00 in fees and $3,468.84 in costs, explaining the original request was excessive and listing multiple concerns (inflated daily hours, redundant pleadings, overbilling compared to other counsel, lack of write-offs, and the coercive rate-increase language).
The court noted the requested total was roughly five times higher than typical observed requests and questioned paying an amount exceeding a year’s public-salary equivalent for one case.
Tolin appealed, arguing the reduction was an abuse of discretion and that his submission met the federal lodestar standard; DFS defended the reduction as within the court’s discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by reducing Tolin’s requested fees from $121,530 to $25,000	Tolin: his filings, affidavit, and billing records show the lodestar (reasonable hours × reasonable rate); statute requires payment	DFS: Tolin failed to prove reasonableness; district court properly exercised discretion to reduce excessive request	Court affirmed: no abuse of discretion; district court properly applied lodestar principles and discretionary adjustments

HJO v. State (In re KMO), 280 P.3d 1203 (Wyo. 2012) (underlying termination decision affirmed)
Tolin v. State (In re NRF), 294 P.3d 879 (Wyo. 2013) (affirming substantial fee reduction; courts must scrutinize fee requests)
Grommet v. Newman, 220 P.3d 795 (Wyo. 2009) (abuse-of-discretion standard for fee awards)
Thorkildsen v. Belden, 269 P.3d 421 (Wyo. 2012) (adoption of federal lodestar test and discretionary adjustments)
Dewey v. Wentland, 38 P.3d 402 (Wyo. 2002) (court may limit contractual fee recovery on equitable grounds)
UNC Teton Exploration Drilling Inc. v. Peyton, 774 P.2d 584 (Wyo. 1989) (courts may scrutinize fee applications closely)
Copeland v. Marshall, 641 F.2d 880 (D.C. Cir. 1980) (billing should not be a mechanical exercise; courts must exercise judgment when fixing reasonable fees)