N.D. Texas cuts commercial fee award 25%, including for block billing

What happened

Balboa Capital Corporation sought $742,434.66 in fees under a contract fee clause, with Hall Griffin LLP as counsel. The court awarded $556,826, a reduction of $185,608.66. It cut $46,294.57 for unrelated claims and $11,625 for block billing. It also found vague entries and duplicative staffing, then reduced the lodestars by 25% and applied a multiplier of 0.75.

What the court said

If the Court assumes that each entry reflects one hour of work, billed at Balboa’s requested hourly rate of $375 per hour, that results in $11,625.00 of additional unrecoverable fees incurred by FBFK beginning in June of 2019

the vagueness of certain entries in Movants’ billing records, discussed previously, undermines the Court’s ability to determine the extent to which the lodestar should be reduced

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

Why it matters

The ruling shows that a fee applicant's time records are central to the lodestar. Courts will reduce specific entries for block billing and vagueness, and may apply a further percentage cut when the records do not let the court separate recoverable work from unrelated or duplicative work.

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 N.D. Texas approves and attorney fee motions in Texas 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.