Wash. Court of Appeals published opinion — 877801 orderandopinion.pdf

Citation: Wash. Court of Appeals published opinion — 877801 orderandopinion.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/877801%20orderandopinion.pdf ↗

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and Santiago stated in their declarations that their proposed hourly rates were based on

their individual experience in debt collection matters, their Seattle location, and inflation.

The Cromars further submitted evidence that the greater Seattle area was the relevant

legal community for rate comparisons. The trial court was otherwise permitted, as it did

here, to employ its own knowledge of what constituted reasonable hourly rates for

Seattle attorneys of similar skill and experience. See Numrich, 197 Wn.2d at 31-32.

Based on the standard of review, we cannot conclude that the trial court abused its

discretion in discounting the hourly rates of the Cromars’ attorneys.

B. Reasonable Hours

The Cromars next contend that the trial court abused its discretion when it did not

apply a proper lodestar analysis in its arbitrary determination that only 16 of 52.9 of

counsels’ hours were reasonably spent on the Cromars’ case.

The trial court provided two grounds for its reduction of the submitted hours: (1)

that the Cromars’ counsels’ case management unnecessarily prolonged the case by

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87780-1-I/14

stunting the possibility of a settlement with TAG Realty and (2) that some of the hours

were spent on unsuccessful efforts. 10 The court erred in both respects.

First, the trial court improperly based the reduction of attorney fees on the finding

that the Cromars’ pursuit of a class action resulted in wasteful and inefficient work

because it restricted the possibility of a negotiated resolution with TAG Realty. To begin,

TAG Realty never argued that the Cromars’ class allegations either resulted in wasteful