E.D. New York cuts commercial fee award 50.1%, including for block billing

What happened

Dorsey & Whitney, counsel for Canon U.S.A., sought $38,053.84 in fees under a contract fee clause for 65.4 hours. The magistrate judge recommended awarding $18,985, a reduction of $19,068.84 or 50.1%. The court lowered the hourly rates it found reasonable, found some hours excessive, and applied a 15% cut for block billing because the records made it difficult to assess the reasonableness of time on individual tasks.

What the court said

the records contain block-billing, which “makes it difficult if not impossible for [the Court] to determine the reasonableness of the time spent on each of the individual services or tasks provided.”

The court also reduced the award for: hourly rate reduced, excessive hours.

Why it matters

The ruling shows that a fee applicant's time records are central to the award: courts may reduce rates and hours for excess, and block-billed entries can draw a separate percentage cut when they obscure how time was spent on specific tasks.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the E.D. New York approves and attorney fee motions in New York 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.