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

What happened

The plaintiff in a Fair Credit Reporting Act case asked for $110,022.75 in attorney fees for 282.6 hours. The court awarded $7,500 and 15 hours, a reduction of $102,522.75, or 93.2%. It found the requested hourly rates unreasonable. It also cited heavily redacted billing entries that gave no understanding of the work, block billing that prevented matching deposition dates to time entries, duplicative services, a 3.00 hour travel entry, hours excessive for a routine claim, and limited success on the summary judgment motion.

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 is unable to even match depositions dates with billing time entries.

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

Why it matters

The ruling shows that a fee award can rest on the time records themselves. Redacted or vague entries and block billing left the court unable to check the work, and the court reduced the award alongside its findings on rates, staffing, travel and results. Precise, unredacted entries let a court match time to tasks.

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.