LeChase Construction Services, LLC. v. Escobar Construction, Inc., 3:18-cv-01021

LeChase Construction Services, LLC sued Escobar Construction, Inc. for breach of a subcontract; Escobar’s counterclaims were dismissed and default judgment was entered against Escobar.
After default, LeChase moved for damages and attorneys’ fees, seeking roughly $3.2M in contract damages plus $83,059 in fees; Escobar did not oppose.
LeChase submitted invoices, assignment documents, and payroll/equipment records to support amounts paid to replacement subcontractors and suppliers after Escobar’s breach.
The Court calculated that LeChase incurred $6,378,259.49 to finish Escobar’s scope, the subcontract value (after change orders) was $7,012,419.79, and LeChase had already paid Escobar $3,895,711.33.
The Court awarded expectation damages of $3,261,550.63 (after crediting amounts that would have been paid had Escobar performed), pre-judgment interest at 9% from August 16, 2018, post-judgment interest under 28 U.S.C. § 1961, and attorneys’ fees of $82,833.00.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether LeChase proved breach-related expectation damages	LeChase argued its replacement costs and assigned claims flowed from Escobar’s breach and supported an expectation-damages award	Escobar did not oppose / no response	Court found LeChase’s evidence sufficient and awarded $3,261,550.63 in expectation damages
Measure of recoverable damages (credit for amounts LeChase would have paid)	LeChase sought full replacement and assigned-claim amounts but acknowledged credit for unpaid subcontract balance	No opposition	Court credited the amount LeChase would have paid ($3,116,708.46) and reduced gross replacement costs to reach the final award
Whether contract permits recovery of attorneys’ fees	LeChase relied on subcontract Sections 31(A), 31(B), and 37, which expressly allow recovery of attorneys’ fees for breach-related costs	No opposition	Court held the subcontract authorizes attorneys’ fees and awards $82,833.00
Whether requested hours and rates are reasonable	LeChase submitted contemporaneous time records and sought partner, associate, and paralegal rates	No opposition; Court examined prevailing district rates	Court found hours reasonable, adjusted paralegal rate from $100 to $90, and awarded $82,833.00 total in fees

In re Residential Capital, LLC, 533 B.R. 379 (S.D.N.Y. 2015) (expectation, reliance, and restitution categories and causation standard for contract damages)
Wechsler v. Hunt Health Sys., Ltd., 330 F. Supp. 2d 383 (S.D.N.Y. 2004) (burden to prove damages caused by breach to a reasonable certainty)
Millea v. Metro-N. R. Co., 658 F.3d 154 (2d Cir. 2011) (lodestar analysis for attorney’s fees)
Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542 (2010) (standards governing reasonable attorney’s fee awards)
Blum v. Stenson, 465 U.S. 886 (1984) (market-based standard for reasonable hourly rates)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (reductions for excessive, redundant, or unnecessary hours)
Alyeska Pipeline Servs. Co. v. Wilderness Soc’y, 421 U.S. 240 (1975) (general rule that prevailing party in contract disputes is not automatically entitled to fees)
Schipani v. McLeod, 541 F.3d 158 (2d Cir. 2008) (state law governs prejudgment interest in diversity cases; federal statute governs post-judgment interest)