E.D. Pennsylvania cuts commercial fee award, including for clerical work
Fieger v. HALL et al, No. 2:24-cv-02410. District Court, E.D. Pennsylvania, Judge Wendy Beetlestone. 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.
Commercial · Sanctions · Fee applicant's counsel: Cherry Law Firm · Figures include costs
What happened
Cherry Law Firm sought sanctions fees for Fieger. The court reduced the hourly rates for Cherry's work and for paralegal time. It disallowed 2.8 hours for communications and corrected one entry from 0.3 to 0.2 hours. It reassigned several clerical entries from the attorney rate to the paralegal rate, including two hours, 30 minutes for a proposed order, and 2.9 hours for compiling billing records, and nullified time for navigating a website. The court stated no totals.
What the court said
Accordingly, two of those hours will be reassigned to the paralegal rate, with the remaining half hour billed at the attorney rate.
time spent preparing the proposed order will be reassigned from Cherry’s fee schedule to the paralegal’s fee schedule, commensurate with the 30 minutes that the paralegal later billed
30 minutes attributable to drafting the proposed order, as billed on July 10, 2026, will be reassigned from the attorney rate to the paralegal rate.
The time billed on July 13, 2026, for compiling the CLS fee schedule will be nullified, as it is unreasonable to bill at an attorney rate for simply navigating to the CLS website
The 2.9 hours that Cherry billed on July 18, 2026, for compiling the firm’s existing billing records and organizing those expenses into the petition are only compensable at the paralegal rate
The court also reduced the award for: hourly rate reduced, hourly rate reduced, excessive hours, excessive hours.
Why it matters
The ruling shows that courts separate clerical tasks from legal work when reviewing time records, reassigning or striking entries billed at attorney rates. It also shows that rate adjustments and excessive or duplicative time can reduce a sanctions award even where the court states no overall total.
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
Fieger v. HALL, No. 2:24-cv-02410 (E.D. Pa. Aug. 11, 2026) See hourly rates the E.D. Pennsylvania approves and attorney fee motions in Pennsylvania 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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