Attorney Fee Award of $1 in Wage Case Rejected on Appeal

A federal judge in Arkansas abused his discretion in awarding one dollar in attorneys’ fees in a $270,000 settlement that resolved Fair Labor Standards Act overtime claims involving more than 160 workers, a divided Eighth Circuit ruled Wednesday.

Judge Billy Roy Wilson failed to calculate the “lodestar,” as is required, before reducing the fees for alleged attorney misconduct and other factors, the U.S. Court of Appeals for the Eighth Circuit said in a 2-1 opinion.

When determining if attorneys’ fees are reasonable, courts must first calculate the lodestar by multiplying the hourly rate by the number of hours worked on ...