Syers Properties III, Inc. v. Rankin, 226 Cal. App. 4th 691

Background

Syers Properties sued its former attorneys (Rankin, Wilkens, Law Offices of Ann Rankin) for legal malpractice and breach of fiduciary duty; after trial the court granted defendants' nonsuit and entered judgment for defendants.
Defendants moved for attorney fees under the parties’ fee agreement and Civ. Code § 1717; they sought $843,245.27 for 2,324.5 hours (primarily 1,949 hours by three attorneys) covering litigation from inception through post-judgment.
Fee support consisted of attorneys’ declarations breaking out hours by categorical work types (e.g., discovery, trial prep), qualifications, and a proffer of market rates based on an adjusted Laffey Matrix; no detailed time records or the actual billing rates paid by the insurer were produced to the public record.
Plaintiff argued the declarations lacked adequate specificity, that defendants’ actual billed rates (paid by insurer) were lower and should control, and that use of the lodestar/Laffey approach was improper for non-contingent hourly-fee insurance-defense work.
The trial court accepted the categorical hour breakdown and the adjusted Laffey Matrix (and supporting attorney declaration) as establishing reasonable hours and rates, awarded the full $843,245.27, and this appeal followed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were defendants’ aggregated, categorical declarations adequate to prove reasonable hours?	Declarations lack detail; must produce billing statements or itemized time to show non-duplicative, reasonable time.	California law permits fee awards based on counsel declarations and judge’s view; categorical breakdown is sufficient.	Court affirmed: trial judge did not abuse discretion; detailed time records not required; categorical declarations and judge's firsthand oversight suffice.
May the court award fees using a market "lodestar" rate above the actual hourly rates billed to an insurer?	Actual billed rates (lower insurer rates) should cap recoverable fees; no contingency risk here to justify above-billed market rates.	Reasonable market rate controls, not the amount actually charged or paid; Laffey-adjusted rates and attorney opinion support market rates.	Court affirmed: market/lodestar rate may exceed insurer-paid rates; trial court reasonably relied on Laffey and attorney declaration.
Was reliance on the adjusted Laffey Matrix permissible?	Laffey is D.C.-based and not controlling; inappropriate to import without more localized evidence.	Laffey can be adjusted for locality; court may adopt it alongside local attorney opinion.	Court affirmed: use of adjusted Laffey plus local attorney declaration was a permissible basis; trial court not required to accept Laffey but did not err in doing so.
Standard of review and deference to trial judge in fee valuation?	N/A (implicit challenge seeks de novo scrutiny).	Fee determinations are reviewed for abuse of discretion; trial judge best positioned to value services.	Court reiterated abuse-of-discretion standard and declined to overturn the judge’s factual and discretionary determinations.

Key Cases Cited

Ketchum v. Moses, 24 Cal.4th 1122 (establishes lodestar as baseline and standard of appellate review for fee awards)
PLCM Group, Inc. v. Drexler, 22 Cal.4th 1084 (market rate governs reasonable hourly rate under Civ. Code § 1717)
Serrano v. Priest, 20 Cal.3d 25 (fee calculation principles and lodestar origins)
Chacon v. Litke, 181 Cal.App.4th 1234 (approves lodestar and awarding fees above actual billed rates)
Nemecek & Cole v. Horn, 208 Cal.App.4th 641 (rejects limiting awards to insurer-paid rates; affirms use of market rates)
In re HPL Technologies, Inc. Sec. Litig., 366 F.Supp.2d 912 (discusses Laffey Matrix and endorses categorical hour reporting as useful compromise)
Raining Data Corp. v. Barrenechea, 175 Cal.App.4th 1363 (confirms declarations may suffice without detailed billing records)