S.D. Florida cuts wage and hour fee award 52.1%, including for clerical work

What happened

The FairLaw Firm requested $22,134.15 in fees for 67.61 hours in this Fair Labor Standards Act case. The court awarded $10,591, a reduction of $11,543.15 or 52.1%. It reduced the hourly rates for Mr. Pollock, Mr. LaRou, and Ms. Sanguino. It declined to award 17.8 hours incurred after July 11, 2024, and 0.3 hours from a June 6, 2024 entry that did not appear to be from this case. It also excluded time entries for clerical or secretarial tasks.

What the court said

the time entries listed below are for non-attorney tasks that are clerical or secretarial in nature and therefore not recoverable

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

Why it matters

The ruling shows that a fee award can be reduced on several independent grounds at once: the hourly rate, hours not tied to the case, and entries for clerical tasks. Courts will examine each time entry and will not compensate work that is secretarial in nature even when an attorney records it.

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

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.