N.D. Texas cuts commercial fee award 25%, including for vague entries | LegalTime AI

N.D. Texas cuts commercial fee award 25%, including for vague entries

Balboa Capital Corporation v. Shafie Transitions MHT LLC et al, No. 3:18-cv-00900. 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, sought $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 vague entries in the billing records that it said undermined its ability to determine the extent of the lodestar reduction.

What the court said

Vague entries · 25% reduction
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 a court may apply a percentage cut to the whole fee request when time entries are too vague to let it assess the lodestar, and that duplicative staffing can support a further reduction. It illustrates that recordkeeping problems can affect the total award rather than only specific line items.

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. Shafie Transitions MHT LLC, No. 3:18-cv-00900 (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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