Jermaine McNeal v. RCM Technologies USA Inc, 2:16-cv-05170

Plaintiffs Jermaine McNeal and Genoa Sosa brought a class action against RCM Technologies (USA), Inc.; the parties reached a proposed settlement.
Plaintiffs moved for approval of $10,000 service awards for each named plaintiff, $120,000 in attorneys’ fees and $10,915.72 in litigation costs.
The Court held a fairness hearing on July 10, 2017; no class members objected to the fee or service award requests.
Class Counsel submitted lodestar billing showing over $123,000 in fees through June 2, 2017, and detailed time entries and hourly rates.
Class Counsel supported the requested awards by describing plaintiffs’ work for the case (document review, mediation attendance, consultations) and by arguing the fees/costs were reasonable and necessary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether $10,000 service awards for each named plaintiff are appropriate	Plaintiffs argued awards compensate work, risk, and time spent representing the class	Defendant did not oppose in the record; no class objections	Court approved $10,000 each as reasonable and proportional to class recovery
Whether attorneys’ fees should be awarded and calculation method	Plaintiffs sought fees and supported lodestar showing hours and rates; argued lodestar appropriate because fees are paid separately	Defendant did not successfully oppose; no objections reported	Court found lodestar method appropriate and supportive of the requested award
Whether Class Counsel’s hourly rates and hours are reasonable	Plaintiffs submitted declarations showing experience, comparable market rates, and detailed time entries totaling >250 hours	Defendant did not successfully challenge rates/hours; no objections reported	Court found counsel’s rates and hours reasonable given experience, tasks performed, and results obtained
Whether $10,915.72 in litigation expenses are recoverable	Plaintiffs provided itemized costs (travel, expert fees, copying, mediation, filing, research) incurred prosecuting the case	Defendant did not object; no class objections	Court approved the expenses as reasonable and necessary

Rodriguez v. West Publishing Corp., 563 F.3d 948 (9th Cir. 2009) (incentive awards common and permissible in class actions)
Staton v. Boeing Co., 327 F.3d 938 (9th Cir. 2003) (factors for evaluating class representative incentive awards)
Hanlon v. Chrysler Corp., 150 F.3d 1011 (9th Cir. 1998) (percentage and lodestar methods for common fund fee awards)
In re Coordinated Pretrial Proceedings in Petroleum Products Antitrust Litigation, 109 F.3d 602 (9th Cir. 1997) (reasonableness is the goal in fee determinations)
In re Bluetooth Headset Products Liability Litigation, 654 F.3d 935 (9th Cir. 2011) (discussion of lodestar and multiplier approach)
Camacho v. Bridgeport Financial, Inc., 523 F.3d 973 (9th Cir. 2008) (hourly rates should reflect rates for attorneys of comparable skill and reputation)
Barjon v. Dalton, 132 F.3d 496 (9th Cir. 1997) (relevant community for rate determination is the district where suit is filed)