§ 1.6.9 TIME SPENT ON FEE PROCEEDINGS

• Jurisdiction: Arizona

The Arizona courts have not established a uniform rule for whether time spent in establishing entitlement to court-awarded attorneys' fees is compensable in the fee award. Under A.R.S. § 12-348, fees expended by a party to establish its entitlement to a fee award under that section are not compensable. A.R.S. § 12-348(H). The federal courts are split as to whether time spent in preparing and prosecuting a fee application is recoverable, although several federal courts have held that under fee shifting...