D. New Mexico cuts civil rights fee award 55.5%, including for vague entries

What happened

The plaintiffs sought $49,632.34 in fees and costs for 54.9 hours. Judge Riggs awarded $22,079.27, a reduction of $27,553.07, and allowed 37.3 hours. The court cut time for unrelated claims, reduced entries that were vague or block billed, and trimmed hours for excessive editing. The figures include costs.

What the court said

Due to the vague time entry, the Court cannot confirm the reasonableness of billing about three-and-a-half times the amount as the prior draft. Therefore, the Court will reduce the entry from 4.1 to 2.05.

Therefore, the Court will reduce the total of the three entries from 7.5 hours to 3.75 hours.

The remaining entries that discuss Plaintiffs' numerous drafts and series of edits run afoul of block billing and are unreasonably vague entries.

Therefore, the Court will reduce the cumulative total for the three entries from 3.2 to 1.6 hours.

The next three entries must be reduced for the same reason as the previous three.

Since Plaintiffs' time entry does not demonstrate that the amount of time spent on each task was reasonable or necessary, the Court will reduce the 8.5 hours to 4.25 hours.

The court also reduced the award for: unrelated claims, unrelated claims, unrelated claims, unrelated claims, unrelated claims, excessive hours, unrelated claims, hourly rate reduced.

Why it matters

The ruling shows that a fee applicant must describe each task with enough detail for the court to assess reasonableness. Entries that combine tasks or leave the work unclear can be cut, and time on claims outside the fee-bearing issue is removed.

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 D. New Mexico approves and attorney fee motions in New Mexico federal courts.

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