E.D. California cuts civil rights fee award over block billing
Estate of Gabriel Strickland et al v. Nevada County et al, No. 2:21-cv-00175. District Court, E.D. California. 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.
Civil rights
What happened
The plaintiffs in a civil rights case sought fees for 10.5 hours of work. The court found that the plaintiffs provided no basis for their assertion that they billed 10.5 hours and that the time entries were block billed. It reduced the requested hours by 30%, awarding 7.35 hours. The court did not state dollar totals for the request or the award.
What the court said
Because plaintiffs provide no basis for their assertion that they billed 10.5 hours, the court determines it is appropriate to reduce the award by 30%.
Why it matters
The ruling shows that courts will cut hours when time entries are block billed and the applicant does not substantiate the hours claimed. A percentage reduction applied to the total hours is a common remedy when the records do not allow the court to separate compensable from non-compensable time.
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
Estate of Gabriel Strickland v. Nevada County, No. 2:21-cv-00175 (E.D. Cal. Sept. 27, 2024) See hourly rates the E.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.
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