D. Arizona cuts commercial fee award 15.1% over clerical work
Brighthouse Life Insurance Company v. Rudolph, No. 2:24-cv-00870. District Court, D. Arizona, Judge Diane J. Humetewa. Decided . Read the opinion
- Requested
- $71,419.50
- Awarded
- $60,605
- Cut
- 15.1%$10,814.50
Commercial · Contract fee clause · Fee applicant's counsel: Womble Bond Dickinson
What happened
Womble Bond Dickinson, counsel for the fee applicant, requested $71,419.5 in fees under a contract fee clause, based on 179.6 hours. The court awarded $60,605, a reduction of $10,814.5, or 15.1%. The court removed 9.5 hours that it found were spent on clerical work billed as legal work, leaving 170.1 reasonable hours for the lodestar calculation. The figures do not include costs.
What the court said
These clerical hours will be removed from the reasonable hours for the lodestar calculations. The total hours after adjusting for hours spent on clerical work is 170.1 hours
Why it matters
The ruling shows that courts will separate clerical tasks from legal work when setting the lodestar, and that time records must distinguish the two. Hours recorded for clerical tasks are removed even when the overall request is otherwise supported.
How to keep this out of your fee petition
- Leave purely clerical work off the fee petition.
- Describe paralegal tasks so the substantive work is clear.
- Split mixed entries into their substantive and clerical parts.
Cite this ruling
Brighthouse Life Insurance Company v. Rudolph, No. 2:24-cv-00870 (D. Ariz. Mar. 25, 2026) See hourly rates the D. Arizona approves and attorney fee motions in Arizona 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.
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