N.D. Texas cuts commercial fee award, including for block billing
Balboa Capital Corporation v. Wahab Transitions MHT LLC et al, No. 3:18-cv-01949. 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 in a commercial case. The court did not state totals. It subtracted $46,294.57 for fees on unrelated claims and $11,625.00 for block billing, then applied a 25% downward adjustment to the lodestar for duplicative staffing and inefficiencies, and a further 25% reduction for vague billing entries that the court said undermined its ability to assess the lodestar.
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 separate specific unrecoverable amounts from percentage cuts. Block billing drew a fixed dollar subtraction, while vague entries and duplicative staffing supported across-the-board reductions, so the quality of time records directly shapes how much of a fee request survives.
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. Wahab Transitions MHT LLC, No. 3:18-cv-01949 (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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