Robert Johnson v. G.D.F., Incorpora, 668 F.3d 927

Johnson, a Domino's Pizza employee in Oak Park, Illinois, filed a 2005 state overtime wage claim under the Illinois Minimum Wage Law and FLSA.
Johnson was fired (or claimed retaliation) during or after the state suit; he later pursued a federal retaliation claim under the FLSA in the Northern District of Illinois.
A three-day trial occurred; the jury awarded Johnson back pay of $1,000 and $4,000 in punitive damages; liquidated damages were contested, and post-trial motions were filed.
Before trial, GDF offered to settle everything for $25,000, which Johnson rejected; the state court later settled for $4,328.77 plus interest and fees.
The sole remaining issue was attorney’s fees; Rossiello sought $112,566.87 in fees and costs; the district court awarded far less after reductions.
This opinion reverses the district court’s lodestar calculation and remands for a new determination of hours, rates, and costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the lodestar hours are reasonably expended.	Johnson (Rossiello) contends most hours were reasonable given trial and appeal.	GDF argues most Rossiello hours were excessive or unnecessary.	Abuse of discretion to deny substantial Rossiello hours; remand for recalculation.
Whether Rossiello's hourly rate is reasonable.	Rossiello claims $600/hour; market-rate proof supports this rate.	District court adopted $375/hour based on challenged-rate precedent.	Remand to determine market rate; use appropriate evidence and avoid blanket exclusions.
Whether Johnson is entitled to costs, including trial costs.	Johnson is entitled to all costs of the action, including trial costs.	Costs should be limited given the trial conduct and early disposition.	Johnson entitled to trial costs; remand for proper costs calculation.

Hensley v. Eckerhart, 461 U.S. 424 (1983) (lodestar and adjustments; reasonable hours and rates)
Spegon v. Catholic Bishop of Chicago, 175 F.3d 544 (7th Cir. 1999) (settlement strategy; not quick-settlement rule applicable here)
Moriarty v. Svec, 233 F.3d 955 (7th Cir. 2000) (consideration of substantial settlement offers in fee awards)
Small v. Richard Wolf Med. Instruments Corp., 264 F.3d 702 (7th Cir. 2001) (distinction between FLSA and Title VII rates; market rate evidence)
Uphoff v. Elegant Bath Limited, 176 F.3d 399 (7th Cir. 1999) (market-rate evidence and fee award considerations)
Jeffboat, LLC v. Dir., Office of Workers' Comp. Programs, 553 F.3d 487 (7th Cir. 2009) (attorney-fee awards and adjustment standards)
Anderson v. AB Painting & Sandblasting Inc., 578 F.3d 542 (7th Cir. 2009) (lodestar methodology and de novo review of rates)
Batt v. Micro Warehouse, Inc., 241 F.3d 895 (7th Cir. 2001) (evidence and evaluation of fee submissions)
Denius v. Dunlap, 330 F.3d 919 (7th Cir. 2003) (market-rate considerations in fee determinations)
People Who Care v. Rockford Bd. of Educ. Sch. Dist. No. 205, 90 F.3d 1307 (7th Cir. 1996) (recognition of market-rate evidence in fee awards)
Thouvenot, Wade, & Moerschen, Inc. v. United States, 596 F.3d 378 (7th Cir. 2010) (abuse of discretion standard and reasonableness of award)
Pickett v. Sheridan Health Care, 2011 WL 6287923 (7th Cir. 2011) (lodestar method and de novo review for fee determinations)