E.D. Pennsylvania cuts sanctions fee award, including for vague entries

What happened

The fee applicant sought sanctions covering 39.9 hours of attorney and staff time. The court reduced the request by 7.9 hours for Mr. Schwahn and 4.2 hours for Ms. Sale because the work concerned unrelated claims. It cut another 2.0 hours for Mr. Schwahn and 0.2 hours for Ms. Sale for other reasons. It also reduced time for vaguely worded tasks and for hours it found excessive. The court did not state dollar totals.

What the court said

I agree that some of these vaguely worded tasks don't appear to be duplicates of work already performed, or if they are, would be excessive.

The court also reduced the award for: unrelated claims, other, excessive hours.

Why it matters

The ruling shows that a fee petition supported by time records can still be cut when entries are too general to show what was done, and when claimed hours appear excessive or tied to claims outside the fee award. Courts will trim specific time rather than accept the total as submitted.

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 E.D. Pennsylvania approves and attorney fee motions in Pennsylvania 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.