E.D. Pennsylvania cuts sanctions fee award 15.1%, including for vague entries

What happened

Stevens & Lee, counsel for Abira Medical Laboratories, sought $19,169.60 in sanctions fees. Judge Chad F. Kenney awarded $16,276.80, a reduction of $2,892.80 or 15.1%. The court halved one 2.20-hour entry and one 1-hour entry as vague, cut a 0.9-hour block-billed entry by about 20% to 3.3 hours, removed 0.1 hours of duplicative review by two attorneys, and reduced 2.8-hour and 3-hour entries each to 2 hours as excessive.

What the court said

the Court reduces by fifty percent Mr. Brunelli's 2.20-hour time entry on May 27, 2025 and Mr. Myers's 1-hour time entry on May 28, 2025

this Court will reduce this time entry by approximately 20 percent to 3.3 hours.

The court also reduced the award for: duplicative staffing, excessive hours.

Why it matters

The ruling shows that even a modest sanctions fee request can be trimmed line by line. Courts will reduce entries that do not describe the work, that combine tasks, that duplicate effort between timekeepers, or that claim more time than the task warrants, and they apply the cuts to specific entries rather than the whole bill.

How to keep this out of your fee petition

• Name the task, the document or person involved, and the purpose.
• Avoid stock phrases that could describe any day in any matter.
• Keep privileged detail general, but specific enough to show the work.

Cite this ruling

See hourly rates the E.D. Pennsylvania approves and attorney fee motions in Pennsylvania federal courts.

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