What is the test for awarding attorneys' fees without hearing expert testimony?

MultiRegion, United States of America

The following excerpt is from Bank of Am., N.A. v. New England Quality Serv., 18-2459 (2nd Cir. 2019):

Finally, Appellants object to the district court's decision to award attorneys' fees without hearing expert testimony as to the reasonableness of the fees sought. "We review a district court's award of attorneys' fees for abuse of discretion." Barbour v. City of White Plains, 700 F.3d 631, 634 (2d Cir. 2012).

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