D. Hawaii cuts commercial fee award 1.3% over block billing

What happened

Yoshimoto Law Group, LLLC, counsel for the fee applicant, requested $181,720.20 in fees. The court awarded $179,343.20, a reduction of $2,377. It struck one block-billed entry of 1.0 hour and $145, and struck 16.1 hours of entries that did not comply with Local Rule 54.2(f)(3). The court recommended the reductions.

What the court said

the Court FINDS that Entry 1 on ECF No. 322-4 at PageID.4179 is inappropriately block billed. Accordingly, the Court RECOMMENDS that this entry be stricken

these entries fail to comply with Local Rule 54.2(f)(3). The Court therefore RECOMMENDS that the above entries be stricken.

Why it matters

The ruling shows that courts will strike time entries that combine tasks or lack enough detail to assess reasonableness, even when the overall reduction is small. It also shows that local fee rules on time record content are enforced entry by entry.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

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

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.