Attorney Fees in a $44 Case?

What do you suppose the high end of “reasonable” is for attorney fees in a successful lawsuit based on about $44 in damages? Supposing that $44 claim settled for $10,500?

If you said attorney fees of $500 are about right, give yourself a gold star. In Harrington v. Payroll Services, Inc., case no. B198883 (2d Dist. Feb. 28, 2008), the trial court found that once class certification was denied, the case was so simple that plaintiff was not entitled to fees at all, let alone the $46k sought.

The court of appeal reverses on entitlement to fees, finding they are statutorily mandated, but that $500 is reasonable. It fixes fees in that amount rather than remand for determination in the trial court.

This case might seem contrary to Cruz v. Ayromloo, decided by another division of the same district, which awarded fees far in excess of the damages awarded and the fee schedule set out in the local rules. But there, the court found nothing unreasonable about the time spent on the case. By contrast, the court in Harrington found the hours unreasonable on their face: “At the risk of understatement, there is no way on earth this case justified the hours purportedly billed by Harrington’s lawyers.”

California Labor & Employment Law Blog has some commentary on how this “levels the playing field” in wage and hour cases.

I’m very curious how this $44 case settled for $10.5k. Any wage & hour practitioners out there — or anyone else — care to speculate?