Paul v. American Liberty Van Lines LLC, 0:19-cv-60512

Plaintiff sued under the Fair Labor Standards Act; all defendants except Shawn Thompson settled and the settlement left attorney’s fees to be determined by the court.
Settling Defendants agreed to pay reasonable attorney’s fees; Plaintiff moved for $7,200 (18 hours × $400/hr).
Settling Defendants did not dispute entitlement but argued fees should be reduced to $3,150 by (1) lowering hourly rate to $350, (2) reducing billed hours to 13.5, and (3) applying a one-third reduction to the lodestar because the settlement was for $2,000 (less than Plaintiff’s claimed damages).
The magistrate judge reviewed prior fee awards for Plaintiff’s counsel and found multiple prior awards at $350/hr; consequently recommended $350/hr as reasonable.
The magistrate reviewed time entries, made specific small reductions (e.g., initial client interview, certain email/review entries, slight reductions tied to including non-settling defendant Thompson in discovery), and concluded 16.1 hours were reasonable.
The magistrate declined to reduce the lodestar for results obtained, finding the lodestar presumptively reasonable and that settling pre-trial justified no further reduction; recommended an award of $5,635.00 (16.1 × $350).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonable hourly rate	Kozolchyk is entitled to $400/hr based on experience and prior awards	$350/hr is the prevailing reasonable rate given community standards and prior awards	$350/hr was reasonable (court relied on prior awards and community knowledge)
Hours reasonably expended	18 hours billed; records justify requested time	Reduce hours to 13.5 and trim entries that are excessive or relate to non-settling defendant Thompson	After targeted reductions, 16.1 hours were reasonable (specific cuts: initial interview to 1.0 hr, small reductions for review of order and discovery tied to Thompson, and excessive email/discovery review entries)
Adjustment for results obtained (lodestar reduction)	No downward adjustment; lodestar should stand	Reduce lodestar by one-third because plaintiff recovered only $2,000, far less than claimed	No reduction; lodestar is presumptively reasonable and early settlement avoided further fees, so $5,635 (16.1 × $350) awarded

Norman v. Housing Auth. of Montgomery, 836 F.2d 1292 (11th Cir. 1988) (establishes lodestar method and court's ability to judge reasonable fees)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (hours reasonably expended × reasonable rate; consider results obtained)
Am. Civil Liberties Union v. Barnes, 168 F.3d 423 (11th Cir. 1999) (fee applicants must exercise billing judgment; courts must exclude excessive entries)
Mayer v. Wall St. Equity Grp., Inc., [citation="514 F. App'x 929"] (11th Cir. 2013) (prevailing FLSA plaintiff is entitled to reasonable attorney's fees)
Martinez v. Hernando Cty. Sheriff's Office, [citation="579 F. App'x 710"] (11th Cir. 2014) (lodestar figure is strongly presumed reasonable)