Inscription Canyon Ranch prevailed in a declaratory judgment action filed by Talking Rock Land. In a separate memorandum decision, the court of appeals affirms. This opinion concerns Canyon Ranch’s fee award. After prevailing on summary judgment, Canyon Ranch asked for almost a million dollars in fees and was awarded $700,000. Canyon Ranch appeals this ruling and contends the trial court’s reduction was an abuse of discretion because the trial court did not expressly find which fees it believes were excessive. The court of appeals holds no such findings are required so long as the record reflects a reasonable basis for the trial court’s decision. A prior decision, McDowell Mt. Ranch Cmty. Ass’n v. Simons, 216 Ariz. 266 (App. 2007), does not impose such a requirement although it circumscribes a trial court’s discretion. (We usually see a discussion on China Doll, but it is not cited here. We are also of the mind the law is settled on this.) The trial court also did not err when relying upon Talking Rock’s proportionality argument, pointing out block billing, and time spent on other cases. Finally, Talking Rock asserted its own fees were merely $400,000. While the better practice when making such a challenge is to provide details for comparison such as comparable tasks, hourly rates, etc., there was still no abuse of discretion. For anyone wondering, the court of appeals awarded additional fees against Talking Rock in its memorandum decision.

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