S.D. Alabama cuts commercial fee award 49.4%, including for vague entries | LegalTime AI

S.D. Alabama cuts commercial fee award 49.4%, including for vague entries

BMO Bank N.A. v. Bryant et al, No. 1:24-cv-00006. District Court, S.D. Alabama, Judge Terry F. Moorer. Decided . Read the opinion

Requested
$23,033
Awarded
$11,659
Cut
49.4%$11,374

Commercial · Contract fee clause · Fee applicant's counsel: Husch Blackwell

What happened

Husch Blackwell sought $23,033 in fees under a contract fee clause for 62.8 hours. The court awarded $11,659, a reduction of $11,374. It excluded 24.5 hours tied solely to a bankruptcy matter, cut 4.9 hours by 50% for vague entries, and adjusted the hourly rates for Ms. Leonard Phifer and Ms. Hutchinson. The court awarded 33.4 hours.

What the court said

Vague entries · 50% reduction
the Court finds a 50% reduction of those billing entries is warranted, resulting in a reduction of 4.9 hours.

The court also reduced the award for: unrelated claims, hourly rate reduced.

Why it matters

The ruling shows courts will separate time tied to unrelated proceedings and reduce entries that do not describe the work with enough specificity, even when the fee request is modest. It also shows that rate adjustments can compound recordkeeping reductions.

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

BMO Bank N.A. v. Bryant, No. 1:24-cv-00006 (S.D. Ala. Apr. 17, 2025)

See hourly rates the S.D. Alabama approves.

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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