SLAPP: $3,250 Fee Award To Winning SLAPP Defendant Was No Abuse Of Discretion

Trial Judge Showed Discretion By Reducing Down The Fee Request Of $5,265 Based On The Hours Requested.

            In Olson v. Sardi, Case No. E071991 (4^th Dist., Div. 2 Apr. 30, 2020) (unpublished), defendant successfully won a SLAPP motion based on a negative review of plaintiff for counseling services to his son, with the review posted on Yelp.  The 4/2 DCA affirmed the SLAPP grant.  Plaintiff also appealed a mandatory fee award of $3,250 to defendant.  That, too, was affirmed because no abuse of discretion was shown:  the trial judge reduced the requested 16.2 hours (total fee request of $5,265) down to 10 hours and found the defense hourly rate of $325 to be reasonable—this showed discretion was exercised.