Key legal question
Whether the reduction of a requested fee note for court-appointed counsel required a reasoned decision under the right to be heard.
Extracted holding
Yes. When the court asks counsel to file a fee note and then departs substantially from it, it must at least briefly explain why the claimed amount is not approved.
Extracted reasoning
A purely lump-sum reduction makes it impossible to see which items or rates were rejected and prevents effective challenge. A cost or compensation decision may be briefly reasoned in simple cases, but not where the court materially deviates from the submitted fee note without explanation.