E.D. New York cuts commercial fee award 40%, including for block billing

What happened

Crayola Properties sought $29,924.37 in fees under a contract fee clause after a default judgment in a breach-of-license case. Judge Nicholas G. Garaufis awarded $17,954.62, a reduction of $11,969.75 or 40%. The court cited block billing in counsel's time records that was not detailed enough to assess reasonableness, staffing in which senior professionals performed most of the work, and 90.0 billed hours, including 41.3 on editing the memorandum of law, that were disproportionate to a standard case resolved by default judgment.

What the court said

the time records submitted by counsel contain many instances of block billing, or aggregating multiple tasks into one billing entry, that are not detailed enough to determine whether billing was reasonable.

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

Why it matters

The ruling shows that a single percentage cut can rest on several grounds at once, so time records with aggregated entries may be weighed alongside staffing and overall hours. It also shows courts comparing billed hours against what a routine default-judgment matter would require.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the E.D. New York approves and attorney fee motions in New York 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.