E.D. New York cuts employment fee award 49.7%, including for clerical work
Figueroa v. Mayflower International Hotel Group, Inc et al, No. 1:23-cv-04729. District Court, E.D. New York, Judge Ramón E. Reyes, Jr.. Decided . Read the opinion
- Requested
- $66,004.33
- Awarded
- $33,205.25
- Cut
- 49.7%$32,799.08
Employment · Fee applicant's counsel: Troy Law, PLLC
What happened
Troy Law, PLLC sought $66,004.33 in attorney fees in an employment case. The court reduced the hourly rates for partner-level, paralegal-level, and associate-level work. It also cut 10% of total hours because Tiffany Troy billed clerical tasks, including scanning and verifying a client ID and setting up and downloading video call recordings, at her full hourly rate. The court awarded $33,205.25, a reduction of $32,799.08.
What the court said
Tiffany Troy engaged in several tasks more appropriate for a paralegal, including scanning and verifying a client ID, and charging her full hourly rate for setting up and downloading recordings of video calls
The court also reduced the award for: hourly rate reduced.
Why it matters
The ruling shows courts will reduce rates and hours when time records mix clerical tasks with legal work and when billing entries do not distinguish between the two. It also confirms that fee awards are calculated using rates the court finds reasonable, not the rates requested.
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
Figueroa v. Mayflower International Hotel Group, Inc, No. 1:23-cv-04729 (E.D.N.Y. May 27, 2026) See hourly rates the E.D. New York approves and attorney fee motions in New York 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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