Lower Discounted Rates Are Not Preclusive On Lodestar Fee Award By Lower Court, With Laffey Matrix Not Having To Be Blindly Followed.
O’Hill Capital v. Phillips, Case Nos. G063268 et al. (4th Dist., Div. 3 Nov. 10, 2025) (unpublished), involved a SLAPP grant to defendants, which triggered a mandatory fee award—if the fees requested were reasonable. Defendants moved for $83,825 in fees but only $47,442 were awarded. On appeal, the appellate court rejected plaintiff’s principal argument that the hourly rates claimed by defense counsel were shackled by lower rates paid to an insurer or discounted rates in general, citing Nemecek & Cole and Syers Properties opinions in dispatching that challenge. However, the appellate court did observe that the lower court did not have to credit the Laffey Matrix on hourly rates as determinative at all. Justice Sanchez authored the 3-0 opinion.