What is the test for determining the appropriate amount of a plaintiff's private attorney general fee?

California, United States of America


The following excerpt is from California Common Cause v. Duffy, 200 Cal.App.3d 730, 246 Cal.Rptr. 285 (Cal. App. 1987):

"[W]hile a trial court has discretion to determine the proper amount of an award, the resulting fee must still bear some reasonable relationship to the lodestar figure and to the purpose of the private attorney general doctrine. If there is no reasonable connection between the lodestar figure and the fee ultimately awarded, the fee does not conform to the objectives established in Serrano III, and may not be upheld." (Press v. Lucky Stores, Inc., supra, 34 Cal.3d at pp. 322, 324, 193 Cal.Rptr. 900, 667 P.2d 704.)

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