This is a very rich case on attorney fees on a number of levels. Never mentioned in the body of the opinion is that this case is the notorious West Publishing/Bar Bri class action case involving state bar examination prep courses. This was a common fund settlement in which the district judge reduced the attorney fees claimed by the class counsel by 70%.
Held: The fee reduction was an abuse of discretion. While the district court correctly applied the lodestar method to review the claimed fees, the district court failed to (1) provide a detailed explanation for the severe reduction, (2) failed to apply a risk-multiplier under Stanger v. China Electric Motor, Inc. 812 F.3d 734 (9th Cir. 2016), and (3) ignored the Kerr reasonableness factors under In re Bluetooth 654 F.3d 945 (9th Cir. 2011).
On remand, the matter was referred to a different district court judge in the interests of promoting the appearance of fairness.