Stratton v. Beck, 30 Cal. App. 5th 901 (2018)

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. 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 and concluded “the parties are to bear their own costs on appeal.” Beck interpreted this language to mean that he had not been ordered to pay Stratton’s attorney’s fees on appeal; Stratton disagreed and requested an additional $57,420 (which he sought to have doubled in light of the complexity of the matter) in appellate attorney’s fees from Beck. In this latest opinion, the Court of Appeal once again sided with Stratton and ordered Beck to pay Stratton’s appellate attorney’s fees in the amount of $57,420.