COA requires trial courts to employ a multi-factor approach when evaluating the reasonableness of attorney fee awards
In Prins v. State Police, the Court of Appeals was evaluating the trial court’s award of attorney fees in a lawsuit over the failure of the state policy to turn over some requested information under FOIA. In considering the attorney fee amount requested by the prevailing plaintiff, the trial court simply found that a reasonable fee for the matter was a “$175 per hour at 70 hours” without any other analysis. On appeal, the Court noted that, in Smith v. Khouri, the Michigan Supreme Court laid out a mutli-factor approach in determining a reasonable attorney fee. In this case, however, there was nothing on the record to suggest that the trial court had engaged in this required approach. The Court of Appeals, therefore, remanded the case for reevaluation of the attorney fee issue pursuant to Smith.