E.D. New York cuts civil rights fee award 52.9%, including for vague entries

What happened

The fee applicant sought $341,640 in attorney fees under 42 U.S.C. Section 1988. Judge Pamela K. Chen awarded $160,899.38, a reduction of $180,740.62 or 52.9%. The court reduced the hourly rate for Solda, reduced Solda's overall hours by 10% for vague entries, applied a 20% reduction for limited success, and cut 54.45 hours billed after November 9, 2023. The awarded hours totaled 429.065 of 667.4 requested.

What the court said

As such, the Court reduces Solda's overall hours by 10% for vagueness.

The court also reduced the award for: hourly rate reduced, limited success, other.

Why it matters

The ruling shows that a court will reduce hours when time entries lack specificity, and that vagueness can draw a percentage cut across the whole request rather than an entry-by-entry adjustment. It also shows fee awards can be reduced for limited success and for work outside the relevant period.

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 E.D. New York approves and attorney fee motions in New York federal courts.

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