In determining the lodestar of an attorney's fee, does the trial court have to identify all fees or hours it is allowing or disallowing?

California, United States of America


The following excerpt is from Check v. Raley'S, A153906 (Cal. App. 2019):

In determining the lodestar, the trial court need not identify which specific fees or hours it is allowing or disallowing. The court " 'has no sua sponte duty to make specific factual findings explaining its calculation of the fee award and the appellate courts will infer all findings exist to support the trial court's determination.' " (Taylor v. Nabors Drilling USA, LP (2014) 222 Cal.App.4th 1228, 1250.) Similarly, the court is not obligated to identify each item it finds to be unreasonable because " ' "[w]e do not want 'a [trial] court, in setting an attorney's fee, [to] become enmeshed in a meticulous analysis of every detailed facet of the professional representation. It . . . is not our intention that the inquiry into the adequacy of the fee assume massive proportions,

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