The case brought a Fair Labor Standards Act (FLSA) claim. The employee (plaintiff) had been awarded $5,000 in compensatory and punitive damages after three-day trial where the employee alleged that he was fired after filing lawsuit seeking overtime wages. In error, the court then calculated a fee award after striking all but four hours out of the 190-hour request by the employee's counsel and reducing requested hourly rate of $600 per hour to $375 per hour.
The Seventh Circuit held that the district court could not base reduction in hours on claim that case would have settled earlier in case had counsel accurately told plaintiff of limited potential damages award where liability in instant case was fully contested. Furthermore, the district court could not reduce the hourly rate where: (1) the district court decided on its own that legal market distinguished between FLSA and Title VII cases based on perception that FLSA cases are easier to prosecute; and (2) the district court limited itself to consideration of only fee awards that plaintiff's counsel had received in contested fee requests.