4th Cir.: Paredes v. Zen Nails-Presumptive Fees Schedules are not Dispositive 

Summary:

In this Fair Labor Standards Act (“FLSA”) case, the Fourth Circuit vacated a fee award that slashed plaintiffs' requested attorneys’ fees by more than half, holding that the district court erred by treating the fee guidelines in the District of Maryland’s Local Rules as “presumptively reasonable” and improperly requiring justification for exceeding them.

After prevailing at trial, plaintiffs Flor Arriaza de Paredes and Francisco Tejada Lopez sought $343,189.85 in fees, supported by declarations and an inflation-adjusted matrix. The district court awarded just $167,115.49. The key dispute on appeal: whether the court lawfully relied on the Local Rules’ Appendix B fee ranges to cabin hourly rates.

The Fourth Circuit found that although district courts may consider local matrices, they cannot elevate them to presumptive status. Doing so effectively replaces the required market-based analysis with a judicially-created baseline untethered from actual prevailing rates. Despite acknowledging plaintiffs’ supporting declarations and complexity of litigation, the district court's repeated reliance on the Local Rule matrix—and its blanket refusal to approve rates above that matrix—tainted the fee determination with legal error.

The panel vacated the fee award and remanded, emphasizing that courts must consider a full range of evidence—declarations, prior awards, surveys, and judicial knowledge—without anchoring to a single, static matrix. The Fourth Circuit also took care to reaffirm the district court’s discretion on remand, but warned that overreliance on outdated matrices increasingly invites reversal.

Commentary:

While this decision does not invalidate presumptive Chapter 13 fees,  it does reaffirm that they are administrative tools—not binding fee caps.   Similarly,  attorneys fees awarded under consumer rights fee shifting provisions,  cannot be dispositively set in stone.    When challenged or exceeded,  courts must instead  assess reasonableness based on the totality of the evidence—not just local tradition or standing orders,   considering  all relevant evidence, including:
Affidavits from consumer attorneys,

• Market surveys or updated fee matrices;

• Prior fee awards in similar cases,

• Complexity and skill involved, and

• The court’s own knowledge.

This strengthens the hand of debtor’s counsel seeking higher fees in complex or non-standard cases and may encourage some courts to revisit decade-old fee schedules that lag inflation and market practice.

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