Is a court entitled to an expert opinion in determining a reasonable fee for services provided?

California, United States of America

The following excerpt is from Dolzhenko v. Valley Temps, Inc., B233449 (Cal. App. 2012):

Appellant argues that respondent's fee award had to be supported by expert opinion regarding the reasonable fee for the services provided. But "judges themselves are deemed to be experts on the value of legal services, and may rely on their own experience about reasonable and proper fees, without resort to expert testimony." (Donahue v. Donahue (2010) 182 Cal.App.4th 259, 276.) Appellant has not demonstrated a need for expert testimony in addition to the expertise of the trial court judge regarding a determination of the reasonable amount of fee to be awarded.

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