We regularly follow McCarthy when we are unable to conduct meaningful appellate review of a fee award. For example, in Lewis v. Beyer , 235 Or. App. 367, 370, 232 P.3d 980 (2010), the trial court awarded "attorney fees of $21,070 representing 60.2 hours at $350.00 per hour," and the defendant challenged that award on appeal. Given the mix of arguments that the parties had made in the trial court, we were unable to meaningfully review the fee award.

The Public Utility Commission (the PUC) appeals from a supplemental judgment of the Marion County Circuit Court awarding attorney fees to plaintiffs Ken Lewis and the Utility Reform Project (URP) after plaintiffs prevailed in an action under ORS 183.490 to compel the PUC to order four utilities to establish “automatic adjustment clauses” pursuant to Senate Bill (SB) 408 (2005) and formerORS 757.268 (2005). In an earlier iteration of this case, Lewis v. Beyer, 235 Or.App. 367, 370–71, 232 P.3d 980 (2010), we remanded the supplemental judgment to the trial court so that the court could provide a more complete explanation of the rationale for its attorney fee award, as required by McCarthy v. Oregon Freeze Dry, Inc., 327 Or. 84, 90–91, 957 P.2d 1200 (1998). On remand, the court explained that the award was based on several statutes as well as equitable principles.

However, in light of the complexity of this litigation and the multiple components that formed the bases for the attorney fee petition and the objections, we conclude that, in this case, in order for us to meaningfully review the trial court award of attorney fees, it was necessary for the trial court to provide more detailed findings and conclusions. See Lewis v. Beyer, 235 Or.App. 367, 370–71, 232 P.3d 980 (2010); see also Squier Associates, Inc. v. Secor Investments, LLC, 196 Or.App. 617, 624, 103 P.3d 1129 (2004). Reversed and remanded.

The pertinent inquiry to be decided in this case, therefore, is not whether plaintiffs' claims arise out of the "same operative facts," which was the inquiry that the trial court focused on in denying plaintiffs' request for attorney fees under ORS 20.082. Rather, the pertinent inquiry is whether plaintiffs' claims are based on separate contracts or on the same contract. Because the trial court did not make a determination on that issue, we decline to do so in the first instance. See Lewis v. Beyer, 235 Or. App. 367, 370-71, 232 P.3d 980 (2010) (because the trial court provided no findings or explanation to support its award of attorney fees, remand was necessary to allow the trial court to make the findings necessary for meaningful appellate review); Bruce v. Cascade Collections, Inc., 199 Or. App. 59, 72, 110 P.3d 587, rev den, 339 Or 66 (2005) (because the trial court improperly based its denial of computer-assisted research expenses as a component of attorney fees on Oregon law, rather than the federal fees-authorizing statute, "affirmance or reversal of the trial court's ruling regarding the recoverability of [such] expenses [was] problematic"; rather, "the best disposition [was] to vacate the supplemental judgment in its entirety, permitting the trial court on remand to reconsider its denial of computer research expenses in light of any additional arguments and amendments to the petition that the court elects to entertain"). We note that the trial court stated in the memorandum decision on reconsideration regarding att