S.D. Florida cuts wage and hour fee award 22.3%, including for vague entries

What happened

The Brennan, Manna, and Diamond Law Firm sought $35,082 in fees under the Fair Labor Standards Act for 140.3 hours. The court awarded $27,268, a reduction of $7,814 or 22.3%, and 123.32 hours. It reduced the hourly rates for the associate, the partners, the paralegal, and the law clerk. It cut a subset of hours by one third as excessive, struck vague time entries it could not assess, and addressed duplicative staffing.

What the court said

And, without sufficient particularity, I cannot assess the time claimed for each activity. Barnes, 168 F.3d at 427. So, those time entries should be stricken.

The court also reduced the award for: hourly rate reduced, hourly rate reduced, excessive hours, duplicative staffing.

Why it matters

The ruling shows that a fee petition can lose value at both the rate and hours stages. Courts will strike entries that lack enough detail to assess the time claimed for each activity, and they will reduce hours found excessive or duplicative even when the overall request is modest.

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

See hourly rates the S.D. Florida approves and attorney fee motions in Florida 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.