D. Connecticut cuts commercial fee award, including for vague entries

What happened

Quarles & Brady, LLP sought fees under a contract fee clause for Charter Practices International, LLC and others against Robb. The court did not state totals. It found the time on the preliminary injunction and contempt motions excessive, subtracted 34 hours already compensated on a motion to compel, and declined to shift fees for several unsuccessful motions. It also found numerous entries vague or collateral and applied a further 33% reduction to a subset of entries for block billing and lack of specificity, plus a 50% reduction for limited success.

What the court said

Numerous entries for this period are not fully compensable because they fail to provide sufficient information to support an award, involve matters collateral to the litigation, or appear excessive.

Other entries for this period are not fully compensable because block billing and a lack of specificity prevent me from finding that the time spent was reasonably necessary to effectively litigate the case. Accordingly, a further reduction of 33% is warranted.

Other entries for this period are not fully compensable because block billing and a lack of specificity prevent me from finding that the time spent was reasonably necessary to effectively litigate the case. Accordingly, a further reduction of 33% is warranted.

The court also reduced the award for: excessive hours, unrelated claims, other, other, unrelated claims, unrelated claims, other, limited success, other.

Why it matters

The ruling shows that a fee applicant must give enough detail for the court to assess whether each entry was reasonably necessary. Where entries are vague or block-billed, the court may reduce a subset of the requested time by a fixed percentage rather than attempt an entry-by-entry review.

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. Connecticut approves.

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.