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