Textainer Equipment Management Limited v. United States, 131 Fed. Cl. 701

Capital sought URA attorney’s fees and costs after a taking judgment against the United States for 258 containers (not all owned by Capital).
The case originated in 2008 with CAI International, Cronos, and Textainer alleging the Army took title to containers leased to TOPtainer without just compensation.
The court later allowed Capital to pursue a takings claim; CAI and Cronos’ claims were rejected for lack of ownership or notice.
A 2014 judgment awarded Capital $485,899.64 on its takings claim; CAI and Cronos claims were denied.
Capital filed an URA application on Nov. 30, 2016 seeking approximately $1.25 million in fees and costs for roughly 2,000 hours of work.
The government urged reductions: lower hourly rates, hours spent for unsuccessful plaintiffs, and insufficiently documented online research costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether URA fees may be awarded using lodestar with LSI Laffey starting point	Capital defends LSI Laffey as starting point per Biery.	Government urges reduced rates using adjusted Laffey matrix and fewer hours.	LSI Laffey starting point approved with reductions
Whether lead-counsel rates should be reduced based on other case work	Capital argues 15% reduction is unwarranted.	Government supports 15% rate reduction to reflect other work.	Rate reduction of 15% applied to lead counsel
What portion of hours attributable to unsuccessful plaintiffs may be excluded	Capital argues most hours were for Capital and attributable to Capital’s claims.	Government argues for substantial reductions for CAI and Cronos work and for Green Eagle defense.	Eliminate hours for Green Eagle and CAI/Cronos-related work; partial reductions for other periods
Whether hours spent on unsuccessful motions and non-capital ownership actions are recoverable	All hours reasonably spent on Capital-related issues were recoverable.	Disallow hours on unsuccessful motions and unrelated research.	Eliminate 112.35, 50.9, 17.25, 16.45, 7.5, and 7 hours as non-recoverable; adjust accordingly
Whether costs, including research costs, are properly documented and recoverable	Research costs are justified and documented.	Costs not sufficiently documented; some research costs disallowed.	Costs and research costs allowed at $11,930.93

Biery v. United States, 818 F.3d 704 (Fed. Cir. 2016) (URAs fees principles; lodestar starting point in URA cases)
Hensley v. Eckerhart, 461 U.S. 424 (Supreme Court 1983) (reasonableness of hours and proportionality in fee awards)