M.D. Tennessee cuts consumer protection fee award 93.2%, including for vague entries

What happened

The fee applicant in Burwell v. Portfolio Recovery Associates sought $110,022.75 for 282.6 hours in a consumer protection case. Judge Eli Richardson awarded $7,500, a reduction of $102,522.75 or 93.2%. The court cited heavily redacted billing entries that gave no understanding of the work, duplicative staffing, travel time billed as work, hours beyond what a fairly pedestrian claim would require, unreasonable hourly rates, and time on the summary judgment motion that warranted disallowance or a drastic discount.

What the court said

Defendant filed heavily redacted billing entries that do not provide the Court with any understanding of what work its counsel did on this matter.

The court also reduced the award for: duplicative staffing, travel time, excessive hours, hourly rate reduced, limited success.

Why it matters

The ruling shows that courts will reduce fee awards sharply when billing records are redacted or vague, and that recordkeeping problems can combine with other issues such as duplicative staffing and excessive hours to produce a cut far larger than any single defect would justify.

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 M.D. Tennessee approves and attorney fee motions in Tennessee 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.