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Long v. Griffin
442 S.W.3d 253
| Tex. | 2014
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Background

  • Griffins sued the Long Trusts over oil and gas ventures, centering on an assignment claim for a working interest.
  • In 2001, two Griffins’ attorneys filed an affidavit claiming 644.5 total hours for a $100,000 fee, with 30% on the assignment claim and 95% intertwined with other claims.
  • A 2003 bench trial largely favored Griffins; trial court awarded $35,000 in attorney’s fees.
  • The Court of Appeals affirmed with modifications; this Court reversed in part and remanded to redetermine fees.
  • On remand, the trial court awarded $30,000 in fees; post-judgment interest began from the 2009 final judgment.
  • The Court of Appeals thereafter treated the fee evidence as sufficient and addressing post-judgment interest from 2003; this Court remands again for redetermination.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether lodestar evidence is legally sufficient Griffins argue lodestar evidence lacks task-specific detail. Long Trusts contend the evidence is insufficient to support the fee amount with task specifics. No legally sufficient lodestar evidence; remand for redetermination.
Can contingency fee support the award here Contingency fee arrangement supports reasonable fees. Contingency fee cannot support the award since no monetary relief was awarded. Contingency fee method cannot sustain the award; remand.
Post-judgment interest issue Interest should accrue from final judgment date. Interest accrues from the original judgment date. Not reached on remand; addressed with fee redetermination.

Key Cases Cited

  • El Apple I, Ltd. v. Olivas, 370 S.W.3d 757 (Tex.2012) (lodestar must include task-level detail and timing)
  • Montano v. City of Laredo, 414 S.W.3d 731 (Tex.2013) (require task-specific time evidence for lodestar)
  • Long v. Castle Texas Production Limited Partnership, 426 S.W.3d 73 (Tex.2014) (postjudgment interest principles clarified)
  • Bocquet v. Herring, 972 S.W.2d 19 (Tex.1998) (declaratory-judgment fees analyzed)
Read the full case

Case Details

Case Name: Long v. Griffin
Court Name: Texas Supreme Court
Date Published: Apr 25, 2014
Citation: 442 S.W.3d 253
Docket Number: No. 11-1021
Court Abbreviation: Tex.