What is the test for "reasonably spent" attorney fees?

California, United States of America


The following excerpt is from Lorenzen v. Vt. Rest., B219625 (Cal. App. 2011):

"[A]bsent circumstances rendering the award unjust, an attorney fee award should ordinarily include compensation for all the hours reasonably spent" in litigating the action to a successful conclusion. (Ketchum v. Moses (2001) 24 Cal.4th 1122, 1132.) "Reasonably spent" means that time spent "in the form of inefficient or duplicative efforts is not subject to compensation." (Id. at p. 1133.)

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