Jon Deutsch v. Jesus Becerra, Incorporated, 17-50109

Deutsch, a serial ADA plaintiff, sued La Mexicana Bakery (Jesus Becerra, Inc.) for parking, signage, and an entrance step that violated the ADA; defendant was served but did not appear and default judgment with an injunction was entered.
Deutsch initially requested $5,500 in attorney’s fees and $700 in costs; the district court ordered each party to bear their own fees and costs.
This Court remanded, holding prevailing civil-rights plaintiffs are presumptively entitled to fees and costs, and instructed the district court to calculate fees and costs.
On remand Deutsch sought $15,500 in fees and $1,236 in costs (including fees/costs for the first appeal); the district court awarded $1,000 in fees and $400 in costs.
Deutsch appealed only two issues: (1) the sufficiency of the district court’s fee award (he limited his fee request on appeal to the original $5,500), and (2) the district court’s refusal to enter an order enforcing this Court’s earlier award of $536 in appellate costs.
This Court affirmed the fee award (finding no abuse of discretion) but vacated the judgment as to appellate costs and instructed the district court to order payment of the $536 taxed by the Fifth Circuit clerk and to include costs taxed for the second appeal.

Issue	Deutsch's Argument	Becerra's Argument	Held
Whether the district court abused its discretion in reducing attorney’s fees	Fee award was inadequately explained and improperly reduced; Deutsch sought original $5,500	District court argued case was routine "cookie-cutter," warranted few hours and lower hourly rate	Affirmed — district court provided a permissible explanation (routine/template litigation); reduction based on time/complexity, not degree of success, was not an abuse of discretion
Whether district court must enforce this Court’s prior appellate-costs award ($536)	The Court already awarded costs on appeal and the clerk taxed $536; district court should enter an order enforcing that award without further documentation	District court declined because Deutsch allegedly failed to provide supporting documentation and it would be inequitable to shift appellate costs to a nonparticipating defaulted defendant	Reversed in part — district court erred; it must modify judgment to include the $536 taxed by the Fifth Circuit clerk and include costs taxed in the second appeal

Perdue v. Kenny A. 559 U.S. 542 (2010) (standards for explanation and reasonableness of fee awards)
Hensley v. Eckerhart 461 U.S. 424 (1983) (degree-of-success principle in awarding fees)
Grisham v. City of Fort Worth 837 F.3d 564 (5th Cir. 2016) (application of fee standards in civil-rights context)
Dean v. Riser 240 F.3d 505 (5th Cir. 2001) (prevailing civil-rights plaintiff presumptively entitled to fees absent special circumstances)
Green v. Administrators of Tulane Educ. Fund 284 F.3d 642 (5th Cir. 2002) (lodestar method for fee calculation)
Johnson v. Georgia Highway Express, Inc. 488 F.2d 714 (5th Cir. 1974) (factors for adjusting lodestar)
Walker v. U.S. Dept. of Housing & Urban Dev. 99 F.3d 761 (5th Cir. 1996) (consideration of Johnson factors)
Fogleman v. ARAMCO 920 F.2d 278 (5th Cir. 1991) (abuse-of-discretion review for costs awards)
Gen. Universal Sys., Inc. v. HAL, Inc. 500 F.3d 444 (5th Cir. 2007) (mandate rule requiring district courts to effect appellate mandates)