W.D. Pennsylvania cuts employment fee award 82.5%, including for clerical work

What happened

Dentons Cohen & Grigsby P.C. sought $38,642.50 in sanctions fees. The court awarded $6,780, a reduction of $31,862.50. It declined fees for 1.3 hours of clerical tasks, including proofreading and sending a deficiency letter, worth $195. It limited fees for work on September 19, 20 and 24, 2024, which preceded the original sanctions motion, cutting $1,428. It also found the amount sought considerably excessive given the limited result achieved, cutting $29,602.

What the court said

The Court declines to award any fees for the administrative task of proofreading and sending a deficiency letter or the entry of "further strategize response to Plaintiff's deficient production set,"

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

Why it matters

The ruling shows courts will separate clerical tasks from legal work and will not award fees for time spent before the motion that generated them. It also shows a court may reduce a sanctions fee request substantially when the hours are not proportional to the result obtained.

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 W.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.