What is the test for reducing an award for attorney's fees?

In the last chapter of this protracted litigation, the district judge (Gershon, J.) reduced appellants' attorney's fees award after we concluded that appellants were entitled to attorney's fees but determined that the initial amount of this award was excessive and thus a remand for the limited purpose of diminishing this award was necessary. See Husain v. Springer, 579 F. App'x 3, 5-6 (2d Cir. 2014). Appellants, unsurprisingly unhappy with this development, now appeal the district judge's revised attorney's fees award, contending that the reductions imposed by the district judge were excessive.

The district court "has wide discretion in determining the amount of attorneys' fees to award; thus, absent an abuse of discretion or an error of law we will not disturb the district court's assessment of the appropriate fee award." Grant v. Martinez, 973 F.2d 96, 99 (2d Cir. 1992). Here, the district court acted within the parameters of our mandate in reducing appellants' attorney's fee award based on a number of characteristics. J.A. 1383-85. In other words, the district court did precisely what we directed, which was "reduce the fee awarded in this case to a reasonable figure, which may well be significantly lower than that originally awarded by the district court." Husain, 579 F. App'x at 7.

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