Does the absence of an explanation of the basis of the lodestar amount in a motion for attorney fees and costs require reversal?

California, United States of America


The following excerpt is from Kamali v. Cal. Dep't of Transp., B247756, c/w B250408 (Cal. App. 2015):

While our review of the trial court's determination would have been facilitated by a more detailed explanation of the basis of the award, the trial court's failure to provide one does not require reversal. (Taylor v. Nabors Drilling USA, LP, supra, 222 Cal.App.4th at p. 1249.) "'We find no California case law . . . requiring trial courts to explain their decisions on all motions for attorney fees and costs, or even requiring an express acknowledgment of the lodestar amount. The absence of an explanation of a ruling may make it more difficult for an appellate court to uphold it as reasonable, but we will not presume error based on such an omission.'" (Id. at p. 1250.)

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