N.D. California cuts ERISA benefits fee award 4.5% over clerical work

What happened

The fee applicant sought $20,745 in attorney fees under ERISA. The court awarded $19,805, a reduction of $940, after deducting 5.2 hours of paralegal time that it found was clerical work billed as legal work. The court applied no other reductions. The figures do not include costs.

What the court said

the Court deducts 5.2 hours of paralegal work time, amounting to a total deduction of $940.00

Why it matters

The ruling shows that courts will separate clerical tasks from compensable paralegal work even in a modest fee request, and that time records must distinguish the two. The small percentage cut also shows that a targeted deduction can resolve a recordkeeping issue without a broader reduction.

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 N.D. California approves and attorney fee motions in California 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.