M.D. Tennessee cuts fee award 84.6%, including for block billing

What happened

Barton LLP, counsel for Apartment Insiders, LLC, sought $23,957.50 in sanctions fees for 63.9 hours. The court awarded $3,699.50, a reduction of $20,258.00 or 84.6%. It found only 15.1 hours were billed for substantive review of discovery production or drafting the relevant motion and related filings, and reduced hours for block billing as to work on the protective order and motion to compel. It then applied a 30% across the board reduction for excessive and duplicative time entries, including excessive conferencing.

What the court said

a reduction in the number of hours billed is both appropriate as to work related to the protective order or the motion to compel and necessary to limit compensation to relevant expenses

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

Why it matters

The ruling shows courts will separate time tied to the sanctioned conduct from time on unrelated claims, and will cut hours when entries combine tasks. It also shows a further percentage reduction can follow even after the compensable hours are narrowed, based on excessive conferencing and duplicative staffing.

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 M.D. Tennessee approves and attorney fee motions in Tennessee 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.