What is the test for establishing that a plaintiff's fees are commensurate with the market rate in the community?

MultiRegion, United States of America

The following excerpt is from K.M. v. Tehachapi Unified Sch. Dist., Case No.: 1:17-cv-01431 LJO JLT (E.D. Cal. 2020):

A fee applicant bears a burden to establish that the requested rates are commensurate "with those prevailing in the community for similar services by lawyers of reasonably comparable skill, experience, and reputation." Blum v. Stenson, 465 U.S. 886, 895 n.11. The applicant meets this burden by "produc[ing] satisfactory evidencein addition to the attorney's own affidavitsthat the requested rates are in line with those prevailing in the community for similar services by lawyers of reasonably comparable skill, experience and reputation." Id.; see also Chaudhry v. City of Los Angeles, 751 F.3d 1096, 1110-11 (9th Cir. 2014) ("Affidavits of the plaintiffs' attorney[s] and other attorneys regarding prevailing fees in the community . . . are satisfactory evidence of the prevailing market rate.")

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