The following excerpt is from Roberts v. City of Honolulu, 938 F.3d 1020 (9th Cir. 2019):
The district court diverged from the applicable standard in discarding the declarations entirely and considering only previous fee awards in determining the prevailing market rate. We expressed disapproval of this approach in Camacho , noting that "a district court abuses its discretion to the extent it relies on cases decided years before the attorneys actually rendered their services." 523 F.3d at 981 (citation omitted); see also Moreno v. City of Sacramento , 534 F.3d 1106, 1115 (9th Cir. 2008) ("If the lodestar leads to an hourly rate that is higher than past practice, the court must award that rate ...").
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