S.D. California cuts consumer protection fee award 16.2%, including for vague entries

What happened

The plaintiff, represented by Auto Fraud Legal Center LLP, requested $27,608 in attorney fees for 69 hours of work. The court awarded $23,138, a reduction of $4,470 or 16.2%. It set reasonable hourly rates for each timekeeper. It also deducted 0.3 hours for vague entries, 0.4 hours and 0.8 hours for clerical work billed as legal work, and 1.3 hours, 0.2 hours, 1.5 hours, and 1.5 hours for excessive billing.

What the court said

The Court cannot determine, due to the lack of description in these billing entries, whether this correspondence with Plaintiff was clerical or non-clerical in nature. The Court accordingly deducts 0.3 hours of Rodriguez's time

The Court accordingly deducts 0.4 hours of Rodriguez's time from Plaintiff's fee award.

The Court accordingly deducts 0.2 hours of Abbenhaus's time and 0.6 hours of Rodriguez's time from Plaintiff's fee award.

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

Why it matters

The ruling shows that courts will reduce fee awards when time entries lack enough detail to distinguish clerical from legal work, and when billing appears excessive. It also confirms that courts may adjust hourly rates to what they find reasonable, even when the overall reduction 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. California approves and attorney fee motions in California 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.