In assessing the reasonableness of a percentage-of-recovery award, what is the test for a reasonable fee?
MultiRegion, United States of America
The following excerpt is from Schueneman v. Arena Pharm., Inc., Case No.: 3:10-CV-01959-CAB-(BLM) (S.D. Cal. 2020):
Six Mexican Workers v. Arizona Citrus Growers, 904 F.2d 1301, 1311 (9th Cir. 1990). When employing their discretion and utilizing the percentage-of-recovery method, federal "courts typically calculate 25% of the [common settlement] fund as the 'benchmark' for a reasonable fee award." In re Bluetooth, 654 F.3d at 942. In assessing the reasonableness
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