D. Arizona cuts intellectual property fee award 5.2% over clerical work

What happened

The fee applicant in Coe v. Red Voice Media Incorporated asked the District of Arizona for $5,235 in attorney fees. The Honorable Steven P. Logan awarded $4,965, a reduction of $270, or 5.2%. The court found that the time records in part sought recovery for clerical tasks, including filing documents, preparing requests for summons, and coordinating service of process. The figures do not include costs.

What the court said

the records in part seek to recover for clerical tasks, such as filing documents, preparing requests for summons, and coordinating service process

Why it matters

The ruling shows that a district court will examine time entries line by line and reduce a fee award when clerical tasks are billed as legal work, even when the overall reduction is small relative to the 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

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