Trial Judge Showed Discretion By Reducing Down The Fee Request Of $5,265 Based On The Hours Requested.
In Olson v. Sardi, Case No. E071991 (4th Dist., Div. 2 Apr. 30, 2020) (unpublished), defendant successfully won a SLAPP motion based on a negative review of plaintiff for counseling services to his son, with the review posted on Yelp. The 4/2 DCA affirmed the SLAPP grant. Plaintiff also appealed a mandatory fee award of $3,250 to defendant. That, too, was affirmed because no abuse of discretion was shown: the trial judge reduced the requested 16.2 hours (total fee request of $5,265) down to 10 hours and found the defense hourly rate of $325 to be reasonable—this showed discretion was exercised.