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Prindle v. Secretary of Health and Human Services
23-0346V
Fed. Cl.
Mar 11, 2025
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Background

  • Dale Prindle filed a petition for compensation under the National Vaccine Injury Compensation Program, alleging a shoulder injury from a 2020 influenza vaccine.
  • The case was previously settled, and Prindle received a compensation award per the parties' stipulation.
  • Petitioner then moved for an award of attorney’s fees and costs totaling $25,594.78, with fee documentation provided.
  • The respondent agreed that statutory requirements for a fee award were met but left the amount to the special master's discretion and did not object to the requested rates or costs.
  • Upon review, the court determined a minor reduction for certain attorney tasks improperly billed at attorney rates instead of paralegal rates.
  • The court awarded $25,307.98 in combined attorney’s fees and costs, to be paid directly to petitioner’s counsel.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Reasonableness of attorney's fees Fees and rates requested are reasonable Statutory requirements met, Minor reduction for some tasks;
and consistent with prior awards amount left to court’s otherwise, fees largely awarded as sought
discretion
Reasonableness of attorney's costs All claimed costs are well-documented No objection All costs awarded in full
Proper billing classification of certain tasks Certain document prep billed as attorney No specific argument Such tasks should be billed at paralegal
work rates; reduction applied

Key Cases Cited

  • Saxton v. Sec’y of Health & Human Servs., 3 F.3d 1517 (Fed. Cir. 1993) (court has discretion to reduce attorney fee requests to a reasonable number of hours)
  • Hensley v. Eckerhart, 461 U.S. 424 (1983) (excessive, redundant, or unnecessary hours should be excluded from fee requests)
  • Broekelschen v. Sec’y of Health & Human Servs., 102 Fed. Cl. 719 (2011) (need not do a line-by-line analysis when reducing fees)
  • Wasson v. Sec’y of Health & Human Servs., 24 Cl. Ct. 482 (1991) (petitioner bears burden of proving fees and costs requested)
Read the full case

Case Details

Case Name: Prindle v. Secretary of Health and Human Services
Court Name: United States Court of Federal Claims
Date Published: Mar 11, 2025
Docket Number: 23-0346V
Court Abbreviation: Fed. Cl.