D. Puerto Rico cuts commercial fee award 64.3%, including for vague entries

What happened

King & Spalding LLP sought $575,022 in fees under a contract fee clause. The court awarded $205,131.50, a reduction of $369,890.50. It cut 3.33 hours from Mr. Unger's time by 30% for entries lacking detail, and reduced a vague PMA entry by 0.33 hours. The court also lowered the hourly rate, finding the defendant did not show California rates were reasonable in this case.

What the court said

To adjust for the problematic King & Spalding entries' lack of detail, the Court will reduce them by thirty percent, for a reduction of 3.33 hours from Mr. Unger's time.

Because the vague PMA entry was one of three task descriptions for a single hour, the Court will simply reduce that hour by 0.33 hours.

The court also reduced the award for: hourly rate reduced.

Why it matters

The ruling shows that time entries lacking detail can draw percentage cuts even when the overall fee request is large, and that the party seeking fees must support the hourly rate it claims. Courts will trim specific entries and adjust rates rather than accept a claimed total.

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 D. Puerto Rico approves.

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