N.D. Texas cuts commercial fee award, including for block billing
Balboa Capital Corporation v. Okoji Home Visits MHT LLC et al, No. 3:18-cv-00898. District Court, N.D. Texas, Judge Barbara M. G. Lynn. Decided . Read the opinion
The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.
Commercial · Contract fee clause · Fee applicant's counsel: Hall Griffin LLP
What happened
Hall Griffin LLP sought fees under a contract fee clause for the FBFK Defendants. The court reduced the lodestar by $46,294.57 for fees on unrelated claims and by $11,625.00 for block billing beginning in June 2019. It then applied a 25% reduction for duplicative staffing and vague billing entries, using a 0.75 multiplier. The court did not state total fees requested or awarded.
What the court said
that results in $11,625.00 of additional unrecoverable fees incurred by FBFK beginning in June of 2019, which should be subtracted from FBFK's lodestar.
the vagueness of certain entries in Movants' billing records ... 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 courts will subtract specific amounts for block billing and unrelated claims, then apply an across-the-board cut when vague entries make precise line-by-line review impractical. Time records that do not separate tasks or claims can cost the fee applicant both targeted deductions and a global reduction.
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
Balboa Capital Corporation v. Okoji Home Visits MHT LLC, No. 3:18-cv-00898 (N.D. Tex. July 29, 2024) 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.
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