M.D. Pennsylvania cuts ERISA benefits fee award 19.1% over vague entries

What happened

The plaintiff in an ERISA benefits case sought $51,704.60 in attorney fees. The court awarded $41,804.60, a reduction of $9,900. It deducted $3,793.50 for twenty entries that were vague, $309 for seven entries that did not identify the purpose of calls, correspondence, or emails, and $5,617.50 for three block-billed entries. The figures do not include costs.

What the court said

The value of the disputed time for the remaining twenty entries to which Defendant appropriately objects on vagueness grounds alone is $3,793.50. Therefore, Plaintiff's fee request will be reduced by this amount.

These entries do not identify a purpose for the calls, correspondence, and/or emails. Therefore, they lack the specificity required by Tenafly and the value of the seven entries will be deducted from Plaintiff's fee request.

Thus, the total deduction for the three entries to which Defendant objects on a 'block-billed' basis $5,617.50,

Why it matters

The ruling shows that a fee petition can lose nearly a fifth of its value when time entries do not state a purpose or combine multiple tasks. Courts require enough detail to assess whether each entry was reasonably necessary, and vague or block-billed records are deducted even when the overall request is otherwise supported.

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 M.D. Pennsylvania approves and attorney fee motions in Pennsylvania federal courts.

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