E.D. Pennsylvania cuts fee award 47.8%, including for block billing | LegalTime AI

E.D. Pennsylvania cuts fee award 47.8%, including for block billing

CT INSTALL AMERICA, LLC v. BORYSZEWSKI et al, No. 5:22-cv-04557. District Court, E.D. Pennsylvania, Judge Lynne A. Sitarski. Decided . Read the opinion

Requested
$14,490
Awarded
$7,560
Cut
47.8%$6,930

What happened

The fee applicant sought $14,490 for 48.3 hours. The court awarded $7,560 for 25.2 hours, a reduction of $6,930 or 47.8%. It excluded a 6.4-hour block-billed entry entirely, struck 7.5 hours of clerical work billed as legal work, halved an entry to 1.1 hours as excessive, and halved reply time to eight hours as excessive. The figures do not include costs.

What the court said

Block billing
Thus, the Court excludes the 6.4-hour entry in its entirety.
Clerical work billed as legal work
Accordingly, the Court strikes the entries, totaling 7.5 hours, in their entirety.
Block billing
Accordingly, the Court strikes the entries, totaling 7.5 hours, in their entirety.

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

Why it matters

The ruling shows that block billing and clerical entries can lead a court to strike time outright rather than trim it, and that courts will also reduce hours they find excessive. It illustrates how the detail and task descriptions in time records directly affect the amount awarded on a fee petition.

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

CT INSTALL AMERICA, LLC v. BORYSZEWSKI, No. 5:22-cv-04557 (E.D. Pa. Oct. 29, 2024)

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

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