T&T Management, Inc. v. Choice Hotels International, Inc.
- John Tunheim
- 0:24-cv-01504
- U.S. District Court · District of Minnesota
- 12
In T&T Management, Inc. v. Choice Hotels International, Inc., Judge John R. Tunheim granted in part the winning defendants' request for attorney's fees and costs, awarding $177,151.65 in fees (reduced by 15% from the amount requested) and $4,362.23 in costs after finding that a senior partner's heavy involvement was not fully justified by the case's complexity.
Businesses or individuals involved in franchise or contract disputes who lose their case and face a fee-shifting provision in their contract, as well as their attorneys, who should be aware that courts may reduce fee awards when senior partners perform work that could reasonably be handled by lower-billing attorneys.
What happened
T&T Management, Inc. v. Choice Hotels International, Inc. arose from a franchise dispute in which T&T Management sued Choice Hotels International and related entities for allegedly breaching geographic exclusivity protections in a hotel license agreement. The court previously dismissed the entire case with prejudice, finding no breach of contract, and judgment was entered in favor of the defendants. The defendants Choice Hotels International, Inc. and Country Inn & Suites by Radisson, Inc. (called the 'Franchisor Defendants') then moved for attorney's fees and costs under the license agreement, which T&T did not dispute authorized such an award to the prevailing party.
The court evaluated the fee request using the 'lodestar' method — multiplying the number of hours reasonably worked by a reasonable hourly rate. T&T challenged the request on several grounds: that hourly rates were too high, that too many hours were billed, that senior attorneys did work that lower-paid staff could have done, that some work was duplicated after the case was transferred from Florida to Minnesota, and that fees should be reduced to exclude work done for a co-defendant (Sunshine Fund Port Orange, LLC) who was not entitled to fees under the license agreement. The court rejected T&T's requests for an evidentiary hearing and a stay of any fee award pending T&T's appeal.
Judge Tunheim found the hourly rates — ranging from $250 to $695 — reasonable for the Minneapolis market given the attorneys' experience and expertise. He declined to reduce fees for excessive hours overall, duplicative work on the second motion to dismiss, or work that also benefited Sunshine. However, Judge Tunheim reduced the total fee award by 15% because the Franchisor Defendants did not adequately explain why a partner with nearly 30 years of experience needed to perform more than half the billed work on a case whose legal complexity was relatively straightforward. The court granted the motion in part, awarding $177,151.65 in attorney's fees and the full undisputed $4,362.23 in costs.
The detailed version
- T&T Management, Inc. v. Choice Hotels International, Inc., Civil No. 24-1504 (JRT/DTS)
- John R. Tunheim, United States District Judge
- August 4, 2025
Background
T&T Management, Inc. ('T&T') held a hotel franchise license with geographic exclusivity protections. Through a series of corporate acquisitions, Country Inn & Suites by Carlson was acquired by Radisson Hotel Group Americas ('Radisson') and then by Choice Hotels International, Inc. ('Choice'). When Choice licensed another hotel (operated by Sunshine Fund Port Orange, LLC) near T&T's hotel, T&T sued for breach of contract. The case was originally filed in the Middle District of Florida, where the court dismissed an early complaint as a 'shotgun pleading' (a complaint that is insufficiently clear about which facts support which claims). After multiple amended complaints and a transfer to Minnesota based on a forum selection clause in the license agreement, the court dismissed the entire action with prejudice in February 2025, finding no breach of contract.
Fee Motion
Following entry of judgment, the Franchisor Defendants (Choice and Country Inn & Suites by Radisson, Inc.) moved for $208,413.70 in attorney's fees and $4,362.23 in costs under the fee-shifting provision of the license agreement. T&T conceded the Franchisor Defendants were prevailing parties entitled to reasonable fees but challenged the amount on multiple grounds. T&T also requested an evidentiary hearing and a stay of any fee award pending its appeal.
Legal Standard — Lodestar Method
The court applied the 'lodestar' method, multiplying the number of hours reasonably expended by a reasonable hourly rate. Excessive, redundant, or unnecessary hours must be excluded. The court has broad discretion and need not achieve 'auditing perfection' but rather 'rough justice.'
Hourly Rates
Counsel's rates ranged from $250 to $695 per hour. T&T argued all rates should be reduced to $275.50. The court found the rates consistent with the Minneapolis legal market, noting that recent Minnesota decisions have approved rates up to $650–$675 per hour for civil litigators, and that the most experienced attorneys (30–35 years of experience) billed the highest rates, with only a small portion of time billed at the top rate. The court declined to reduce rates.
Hours Expended — Four Challenged Categories
1. Excessive Hours Overall: T&T argued the case was a simple breach of contract matter that ended at the motion to dismiss stage. The court disagreed, finding the litigation was complicated by corporate acquisitions, a venue transfer, and multiple amended complaints, some necessitated by T&T's own deficient pleadings. No reduction for excessive hours overall.
2. Excessive Work by Senior Attorneys: Partner Craig P. Miller (nearly 30 years of experience) billed 55% of the hours; associate Jackson R. Hobbs billed 33%. T&T argued lower-billing attorneys could have done much of this work. The court agreed as to Miller, finding the Franchisor Defendants did not adequately explain why a senior partner with almost three decades of experience needed to perform the majority of work on a legally straightforward breach of contract case. The court applied a 15% reduction to the entire fee award to account for this. The court declined to reduce Hobbs's hours because his rates ($385–$418/hour) were substantially lower and more in line with what T&T argued was appropriate.
3. Duplicative Work: T&T claimed approximately $9,024.90 in fees were duplicative because the second motion to dismiss (filed in Minnesota) largely repeated the first (filed in Florida). The court found the billing records showed meaningful differences — conforming to Minnesota local rules and addressing factual developments — and declined to exclude those fees.
4. Work Benefiting Defendant Sunshine: T&T argued fees should be reduced by one-third because some work benefited all three defendants, including Sunshine, which was not a party to the fee-shifting license agreement. The court noted the Franchisor Defendants had already excluded fees billed solely to Sunshine and represented that shared work would have been performed regardless of Sunshine's involvement. The court declined to further parse the billing records, finding T&T identified no specific additional fees requiring reduction.
Evidentiary Hearing
Denied. The court has broad discretion in fee matters and the Supreme Court has cautioned that fee disputes should not become a 'second major litigation.'
Stay Pending Appeal
Denied. T&T did not demonstrate irreparable harm — harm without an adequate legal remedy. Because any harm to T&T from paying fees could be compensated with money, a stay was not warranted.
Award
- Attorney's fees: $177,151.65 (the requested amount reduced by 15%) - Costs: $4,362.23 (undisputed; awarded in full) - Motion granted in part.
Reviewer note from the AI+
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.