Remand Was Required.
In Guerrero v. Crown Energy Services, Inc., Case Nos. D076299/D077201 (4th Dist., Div. 1 July 7, 2021) (unpublished), a single FEHA plaintiff won a compensatory damage verdict of $207,855.60 and a punitive damage verdict of $900,000 against defendants. Plaintiff moved for $553,835 in lodestar fees enhanced by a 2.0 positive multiplier, for a total request of $1,107,671. The trial judge awarded $342,284 in fees, denying a positive enhancement because it was a single-plaintiff case. The 4/1 DCA reversed, because it chronicled many cases and found that a positive multiplier is not per se unallowable in a single-plaintiff case. A remand will occur to reassess the multiplier request.
