Tapia v. Blch 3rd Ave. LLC., 1:14-cv-08529

Plaintiffs Tapia, Balderas, and Castillo sued BLCH 3rd Ave. LLC under the FLSA and NYLL for unpaid minimum and overtime wages, spread-of-hours pay, reimbursement for tools, and deficient wage notices; one-day bench trial was held.
The Court found BLCH liable (but not the individual defendants) and awarded aggregate damages of $116,440.89 to the three plaintiffs.
Plaintiffs moved for attorney's fees and costs, initially seeking $28,500 in fees and $2,250 in costs (billing records showed $28,550 in fees).
Plaintiffs submitted contemporaneous billing records for four attorneys and a paralegal totaling 74.95 hours and $28,550 in fees billed at rates of $450 (partner), $400 (senior associate), $375 (associates), and $200 (paralegal).
The Court reduced the requested hourly rates (to $400, $350, $250, and $100 respectively), found the hours reasonable, awarded $19,872.50 in attorney’s fees plus $2,250 in costs, and directed entry of judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are plaintiffs entitled to attorneys' fees and costs?	Prevailing plaintiffs under FLSA and NYLL are entitled to reasonable fees and costs.	Denied only costs contested; did not dispute entitlement generally.	Yes; prevailing plaintiffs entitled to fees and costs.
Are the hourly rates charged reasonable?	Firm sought market rates ($450/$400/$375/$200).	Rates are excessive for routine FLSA matter; should be reduced.	Court reduced rates to $400, $350, $250, and $100.
Are the hours billed reasonable?	74.95 hours for multi-plaintiff case culminating in one-day trial were reasonable.	Sought further reduction arguing limited success.	Hours were reasonable and not reduced.
Should overall fee be further adjusted for limited success?	Full fee appropriate given significant recovery.	Reduce fee because plaintiffs failed to prove liability of individual defendants.	No further reduction; adjusted hourly rates sufficed.

Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany, 522 F.3d 182 (2d Cir. 2008) (framework for determining presumptively reasonable attorney's fee)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (lodestar method—hours reasonably expended times reasonable hourly rate)
Perdue v. Kenny A., 559 U.S. 542 (U.S. 2010) (reasonable fee must be sufficient to attract competent counsel)
Gortat v. Capata Brothers, Inc., [citation="621 F. App'x 19"] (2d Cir. 2015) (lodestar approach applies in FLSA cases)
Scott v. City of New York, 643 F.3d 56 (2d Cir. 2011) (requirement of contemporaneous billing records for fee applications)