E.D. New York cuts employment fee award 64.9%, including for block billing

What happened

The plaintiff sought $365,400 in fees under 42 U.S.C. Section 1988. The court reduced the hourly rate and cut the remaining 634 non-appeal hours by 70%, to 190.2 hours, citing excessive hours, block billing, vague entries, and clerical work billed as legal work. It also cut travel time by 10%. The court awarded $128,370.54, a reduction of $237,029.46, or 64.9%, and awarded 252.2 of 696 hours requested.

What the court said

the amalgamation of tasks without time breakdowns here improperly hinders a court's review

Plaintiff's objection to the R. & R.'s stance that certain time entries were "vague and confusing" is not a valid objection

the R. & R.'s conclusion that plaintiff "repeatedly overbilled" for administrative and clerical tasks

The court also reduced the award for: hourly rate reduced, excessive hours, travel time.

Why it matters

The ruling shows that a single percentage cut can rest on several time-record problems at once, so block billing, vague entries, and clerical tasks may not be separated when a court trims hours. It also shows courts will reduce hours for excess before applying the rate.

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.

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