In E&A Utilities, Inc. v. Joe, No. 14-08-00890-CV, 2010 WL 2901711 (Tex. App.--Houston 14th Dist. 2010, no pet) (mem. op.), the Fourteenth Court of Appeals held that the evidence was factually sufficient to support the jury's award of $2,000 in attorney's fees, even though the requested amount was $11,400.
The Court recognized that the attorney's hourly rate was reasonable because it had not been controverted.
However, the court concluded that facts and circumstances weighed against awarding the requested amount of fees. Id.
The Court pointed to the attorney's admission that there were few documents filed in the case and that discovery was minimal. Id. Moreover, the attorney's fees sought were more than double the quantum meruit award. Id.