N.D. Texas cuts commercial fee award 25%, including for vague entries
Balboa Capital Corporation v. Ortega Home Visits MHT LLC et al, No. 3:18-cv-00909. District Court, N.D. Texas, Judge Barbara M. G. Lynn. Decided . Read the opinion
- Requested
- $742,434.66
- Awarded
- $556,826
- Cut
- 25%$185,608.66
Commercial · Contract fee clause · Fee applicant's counsel: Hall Griffin LLP
What happened
Hall Griffin LLP, counsel for the fee applicant, requested $742,434.66 in fees under a contract fee clause, based on 1,886.9 hours. The court awarded $556,826, a reduction of $185,608.66, or 25%. The court reduced the lodestar by 25% and applied a multiplier of 0.75, citing duplicative staffing and the vagueness of certain billing entries, which the court said undermined its ability to determine the extent of the reduction.
What the court said
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: duplicative staffing.
Why it matters
The ruling shows that vague time entries can affect a fee award even when the court applies an across the board percentage cut rather than striking specific hours. Courts may treat unclear billing records as limiting their ability to assess the lodestar, and the reduction can be folded into a single percentage applied to the total.
How to keep this out of your fee petition
- Name the task, the document or person involved, and the purpose.
- Avoid stock phrases that could describe any day in any matter.
- Keep privileged detail general, but specific enough to show the work.
Cite this ruling
Balboa Capital Corporation v. Ortega Home Visits MHT LLC, No. 3:18-cv-00909 (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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