What is the legal test used to determine a reasonable attorney fee under section 1794, subdivision (d)?

California, United States of America


The following excerpt is from Fuller v. FCA US LLC, B286224 (Cal. App. 2019):

To determine a reasonable attorney fee award under section 1794, subdivision (d), the court uses the standard "lodestar adjustment method." (Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 997 (Doppes).) Under that methodology, the court begins with "a lodestar figure based on the reasonable hours spent, multiplied by the hourly prevailing rate for private attorneys in the community conducting noncontingent litigation of the same type." (Ketchum v. Moses (2001) 24 Cal.4th 1122, 1133 (Ketchum).) The lodestar "is the basic fee for comparable legal services in the community." (Id. at p. 1132.) It may be adjusted upward or downward based on various factors, including "(1) the novelty and difficulty of the

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