S.D. Florida cuts wage and hour fee award, including for clerical work | LegalTime AI

S.D. Florida cuts wage and hour fee award, including for clerical work

Caron et al v. Unlimited Health Care Services, Inc. et al, No. 0:24-cv-60506. District Court, S.D. Florida, Judge Patrick M. Hunt. Decided . Read the opinion

The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.

Wage and hour · Fair Labor Standards Act

What happened

Counsel for the plaintiffs in a Fair Labor Standards Act case asked for attorney fees, and the court did not state checkable totals. The court recommended an hourly rate for Mr. Kozolchyk consistent with its prior recommendation and an hourly rate for Mr. Cuthbertson. It also recommended a 30% reduction to total hours because some billed work was clerical, such as coordinating schedules, basic communications, and procedural matters, and because the claimed hours were somewhat excessive.

What the court said

Clerical work billed as legal work · 30% reduction
the Court has previously denied counsel's requests to collect legal fees for work that consisted of coordinating schedules, basic communications, and procedural matters usually performed by legal assistants, not lawyers.

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

Why it matters

The ruling shows that courts will reduce hours when time records include tasks usually handled by legal assistants and when claimed hours appear excessive, and that a single percentage cut can address both problems at once.

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

Caron v. Unlimited Health Care Services, Inc., No. 0:24-cv-60506 (S.D. Fla. Aug. 3, 2026)

See hourly rates the S.D. Florida approves and attorney fee motions in Florida 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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