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 William P. Dimitrouleas. 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 sought attorney fees under the Fair Labor Standards Act. The court set hourly rates for Mr. Kozolchyk and Mr. Cuthbertson. It then reduced the claimed hours by 30% because some entries were for clerical tasks such as coordinating schedules, basic communications, and procedural matters, and because some time on docket review and similar simple functions was excessive. The court did not state total dollar amounts.
What the court said
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 separate clerical tasks from legal work and will trim hours that appear excessive even when the requested rates are otherwise accepted. Time entries that group scheduling, communications, and routine procedural tasks with legal analysis can lead to a percentage cut across the whole request.
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. 18, 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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