PLCM Group, Inc. v. Drexler

David Drexler (defendant), an attorney insured under a malpractice policy from PLCM Group (plaintiff) with a $20,000 deductible and a fee-shifting provision for deductible-collection litigation, failed to pay his full deductible after submitting a malpractice claim; PLCM sued to recover about $10,320 using its own in-house counsel, and after Drexler rejected settlement and engaged in extensive litigation, PLCM won at trial and sought $61,050 in fees calculated by multiplying a prevailing $185 hourly rate by hours expended (the lodestar method). Drexler argued in-house counsel fees weren't recoverable, but the trial court awarded the full amount, and Drexler appealed.