D. Arizona cuts fee award 59%, including for block billing
arrivia Incorporated et al v. Rowley et al, No. 2:23-cv-01039. District Court, D. Arizona, Judge Douglas L. Rayes. Decided . Read the opinion
- Requested
- $72,014
- Awarded
- $29,541.83
- Cut
- 59%$42,472.17
Sanctions · Fee applicant's counsel: Kirkland & Ellis LLP
What happened
Kirkland & Ellis LLP sought $72,014 in sanctions fees for 178 hours. The court awarded $29,541.83, a reduction of $42,472.17 or 59%. It cut $15,721.50 for 24 entries totaling 31.1 hours. It applied a one-third reduction to every block-billed entry, citing overstaffing and redundant work. It then reduced the lodestar by one third for limited success, bringing the award to $29,541.83.
What the court said
Given that Plaintiffs' counsel overstaffed this specific matter and submitted block-billed time entries that involves redundant work, the Court will apply a one-third reduction to every block-billed time entry.
The court also reduced the award for: other, duplicative staffing, limited success.
Why it matters
The ruling shows that block-billed entries can draw a flat percentage cut rather than an entry-by-entry review, and that courts may combine that with separate reductions for overstaffing and limited success. It also shows that a single set of time records can be reduced on several grounds at once.
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
arrivia Incorporated v. Rowley, No. 2:23-cv-01039 (D. Ariz. June 14, 2024) See hourly rates the D. Arizona approves and attorney fee motions in Arizona 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.
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