Myers v. SSC Westland Operating Company, LLC, 2:13-cv-14459

Plaintiff Asia Myers sued employers under the Pregnancy Discrimination Act and ADA; discovery requests served in Aug–Sept 2014 and new deadline agreed for Oct 27, 2014.
Defendants failed to timely respond; Myers moved to compel on Nov 13, 2014; Defendants did not file a substantive response but later sought 21 more days and produced partial responses in late February 2015.
At a March 4, 2015 hearing the Court found many responses improper (general objections, referral to initial disclosures) and granted the motion to compel, directing Plaintiff to submit a bill of costs under Fed. R. Civ. P. 37.
Plaintiff sought $10,176.96 in fees across four attorneys (total 26.73 hours; rates $300–$500/hr). Defendants objected, arguing sanctions were inappropriate, rates unreasonable, and hours duplicative.
The magistrate applied the lodestar method, reduced recoverable hours to 4.25 (25% of claimed time) because most time was excessive or not "incurred in making the motion," and adopted a blended hourly rate of $380.73.
Recommendation: award $1,614.30 in reasonable fees, payable by Defendant and defense counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to Rule 37 fees	Myers sought fees because Court granted her motion to compel after defendants failed to respond	Defendants contended sanctions not appropriate and their nondisclosure was justified	Court held Rule 37 fees required; defendants gave no substantial justification and Plaintiff attempted to obtain discovery before motion
Reasonable number of hours	Counsel billed 26.73 hours (≈17 for the motion itself) across four attorneys	Defendants argued hours were duplicative and excessive	Court found most time excessive/duplicative; limited recoverable time to 4.25 hours (25% of claimed time) because only hours "incurred in making the motion" are recoverable
Reasonable hourly rate	Requested rates $300–$500/hr (avg $380.73); counsel are experienced civil-rights litigators	Defendants challenged reasonableness of rates	Court found $380.73/hr reasonable based on attorneys' experience and local market data
Award amount and payment responsibility	Requested full billed amount (~$10,177)	Objected to amount and sought reductions	Recommended award of $1,614.30 (4.25 hrs × $380.73/hr), payable by defendant and defense counsel

Hensley v. Eckerhart, 461 U.S. 424 (1983) (lodestar method and exclusion of hours not "reasonably expended")
Blum v. Stenson, 465 U.S. 886 (1984) (reasonable hourly rate measured by prevailing market rate)
Ellison v. Balinski, 625 F.3d 953 (6th Cir. 2010) (lodestar method governs fee calculation)
Adcock–Ladd v. Secretary of Treasury, 227 F.3d 343 (6th Cir. 2000) (fee awards must avoid windfalls and reflect prevailing market)
Downey v. Clauder, 30 F.3d 681 (6th Cir. 1994) (civil contempt sanctions enforce compliance and compensate injured parties)
Wayne v. Village of Sebring, 36 F.3d 517 (6th Cir. 1994) (district court has broad discretion to determine reasonable hourly rates)