Beck v. Stratton, 9 Cal. App. 5th 483 (2017)

Anthony Stratton filed a claim against Thomas Beck with the labor commissioner for unpaid wages in the amount of $303.55. After conducting an administrative hearing, the labor commissioner awarded Stratton $303.50 plus an additional $5,757.46 in liquidated damages, interest and statutory penalties for a total award of $6,060.96. Beck then filed an appeal in the Los Angeles Superior Court, which resulted in an award to Stratton in the amount of $6,778.85, exclusive of attorney’s fees and costs. The trial court subsequently awarded Stratton $31,365 in attorney’s fees. In this appeal, Beck asserted that the attorney’s fees motion, which was filed 58 days after the judgment was entered, was untimely and that the fees sought were unreasonably high. The Court of Appeal rejected both arguments and affirmed the judgment in favor of Stratton. See also Quiles v. Parent, 10 Cal. App. 5th 130 (2017) (award of attorney’s fees and costs need not be bonded pending appeal of same).