Question juridique clé
Whether the fee award for appointed counsel had to be reasoned despite a cost-note being filed
Solution extraite
Yes. Because a specified cost-note had been filed and the court reduced the requested compensation without explaining the specific reductions, a reasoning duty existed and was violated.
Motifs extraits
As a rule, compensation of appointed counsel need only be summarized or not reasoned at all. But if the court departs from a filed cost-note and sets the fee at a non-standard amount, it must at least briefly explain why the reduced items were unnecessary. That did not happen here.