E.D. Louisiana cuts employment fee award 26.8%, including for vague entries

What happened

The plaintiff in a Title VII employment case asked for $209,048.08 in fees and costs. Judge Lance M. Africk awarded $153,128.58, a reduction of $55,919.50. The court discounted $800 for two unaccounted hours, $5,200 for a duplicative entry, and $315 for an entry it found not illuminating as to subject matter. It cut discovery fees by 50% ($3,100.75), applied a five-hour reduction ($1,125), reduced non-working travel time by 50% ($4,557.50) and other travel by 30% ($1,082.25), then applied a final 5% reduction ($8,059.40).

What the court said

That description is “not illuminating as to the subject matter,” and therefore $315.00 in associated fees may be discounted.

The court also reduced the award for: excessive hours, duplicative staffing, excessive hours, excessive hours, travel time, travel time, other.

Why it matters

The ruling shows that a fee award can be reduced on several separate grounds at once, including entries too vague to show the subject matter, duplicative billing, and travel time, and that courts may apply a final percentage cut to the lodestar after itemized reductions.

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 E.D. Louisiana approves and attorney fee motions in Louisiana federal courts.

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