Employment: Denial Of Multiplier In Single-Plaintiff FEHA Case, Simply Based On One Plaintiff Case, Was An Abuse Of Discretion

Remand Was Required.

            In Guerrero v. Crown Energy Services, Inc., Case Nos. D076299/D077201 (4^th Dist., Div. 1 July 7, 2021) (unpublished), a single FEHA plaintiff won a compensatory damage verdict of $207,855.60 and a punitive damage verdict of $900,000 against defendants.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.