The Fourth Appellate District reversed a judgment. The court held that the trial court erred in refusing to entertain a motion for supplemental attorney fees, sought under the private attorney general doctrine, following the plaintiffs’ successful appeal. The trial court also erred in reducing the awards for trial work based on comparable fees for local counsel and for appellate work based on its conclusion that such work was merely “duplicative” of the trial work.

Center for Biological Diversity, Inc. and others (CBDI) sued the County of San Bernardino, challenging the county’s approval of a development project. CBDI was represented by the Santa Monica law firm Chatten-Brown & Carstens, which primarily represents environmental and community groups. The trial court granted CBDI a peremptory writ of mandate ordering the county to vacate and set aside its project approval. The county and developer Hawarden Development Company appealed.