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
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.
More rulings like this
- D. Arizona cuts wage and hour fee award 5.3% over clerical work Zommick v. Lewis Construction Company LLC et al · Oct 2, 2026
- M.D. Tennessee cuts intellectual property fee award 12%, including for vague entries Livingston v. Jay Livingston Music, Inc., et al. · Sep 28, 2026
- E.D. Pennsylvania cuts wage and hour fee award 91%, including for clerical work LIN v. LEES HOUSE RESTAURANT INC et al · Sep 28, 2026