How have courts in the 9th Circuit treated attorney's fees when calculating the amount awarded by a district court?

MultiRegion, United States of America

The following excerpt is from Barnard v. Theobald, D.C. No. 2:03-cv-01524-RCJ-LRL, No. 11-16625, No. 11-16655 (9th Cir. 2013):

"We have long held that district courts must show their work when calculating attorney's fees." Padgett v. Loventhall, 706 F.3d 1205, 1208 (9th Cir. 2013). Failure to

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thoroughly explain the basis for an attorney fees award is problematic because without such an explanation, "it is simply not possible for this court to review such an award in a meaningful manner. Absent some indication of how the district court's discretion was exercised, this court has no way of knowing whether that discretion was abused." Id. (quoting Chalmers v. City of L.A., 769 F.2d 1205, 1213 (9th Cir. 1986)).

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