California Civil Code section 1794(d) is the engine of the state's lemon-law economy: a prevailing buyer recovers attorney's fees and costs from the manufacturer, separate from their own recovery. It's why lemon lawyers can take cases with no money down — and why fee motions are this publication's richest public source.

Three recent fee rulings, with the numbers

Serna v. American Honda (Santa Barbara County, 23CV04753). The case settled for $50,000. The court then awarded the owner's firm, Quill & Arrow LLP, $26,059 in fees plus $1,603.76 in costs — $27,662.76 paid by Honda on top of the settlement.¹

Kelly v. Kia (Sonoma County, 24CV04577). Kia settled for $33,577.33. The court awarded plaintiff's counsel John Hendrickson — at a rate of $600/hr it found reasonable — $34,650 plus $806.76 in costs — $35,456.76. The lawyer's award exceeded the consumer's settlement.²

Yarovoy v. Tesla (N.D. Cal., 3:23-cv-04182). Attorney Daniel T. LeBel got Tesla to agree to a $65,000 buyback of a 2014 Model S purchased for $80,766. On fees, counsel sought $37,462.50; the court approved his $675/hr rate but awarded $14,436.25 in fees plus $554.60 in costs — courts scrutinize the hours, and awards can land well below the ask.³

What this means

• For owners: a legitimate lemon claim does not cost you your recovery. Fee-shifting is the point of the statute.
• For readers of this publication: every fee ruling is a window into a settlement someone intended to keep confidential. We read them so you don't have to.
• The caveat: fee awards become public mostly when fees are disputed — a nonrandom slice of all cases.

The settlement is between the parties. The fee motion is between the lawyers and the court — and the court's file is public.