D. Massachusetts cuts commercial fee award, including for block billing | LegalTime AI

D. Massachusetts cuts commercial fee award, including for block billing

Dairy Farmers of America, Inc. v. Bernon Land Trust, LLC, No. 1:22-cv-10422. District Court, D. Massachusetts, Judge Julia E. Kobick. Decided . Read the opinion

The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.

Commercial · Contract fee clause

What happened

Dairy Farmers of America sought fees under a contract fee clause in its case against Bernon Land Trust. The court did not state dollar totals. It reduced the fees-on-fees request by 70% for work on the fee petition, applied an 11.62% global reduction for time spent on unrelated lease claims, and applied a 20% global reduction for time on non-core work and for block billing.

What the court said

Block billing · 20% reduction
The Court concludes that a 20% global reduction is warranted to account for the time that Dairy Farmers’ counsel devoted to non-core work and to sanction their use of block billing.

The court also reduced the award for: fees on fees, unrelated claims, other.

Why it matters

The ruling shows that block billing can draw a global percentage cut across an entire fee request, not just a line-by-line trim. It also shows courts separating time on unsuccessful or unrelated claims and scrutinizing fees-on-fees work, with each problem producing its own reduction.

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

Dairy Farmers of America, Inc. v. Bernon Land Trust, LLC, No. 1:22-cv-10422 (D. Mass. Oct. 28, 2025)

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