D. Oregon cuts wage and hour fee award 23.2%, including for vague entries
Freeman et al v. Smith et al, No. 3:18-cv-00372. District Court, D. Oregon, Judge Beckerman. Decided . Read the opinion
- Requested
- $725,140.50
- Awarded
- $556,853
- Cut
- 23.2%$168,287.50
Wage and hour · Fair Labor Standards Act
What happened
The plaintiffs in this Fair Labor Standards Act collective action asked for $725,140.50 in attorney fees. The court awarded $556,853, a reduction of $168,287.50 or 23.2%. It lowered the hourly rates for two attorneys. It reduced routine email and phone call entries by about 30% for vague, inadequately described, clerical, and incremental billing, and disallowed 149.8 hours of clerical document review and proofreading.
What the court said
To account for counsel's vague, inadequately described, clerical, and incremental billings entries, the Court imposes a reduction of approximately thirty percent to the routine email and phone call entries
To account for counsel's vague, inadequately described, clerical, and incremental billings entries, the Court imposes a reduction of approximately thirty percent to the routine email and phone call entries
the Court concludes that Lauzier's forty-nine entries and 149.8 hours reviewing, proofreading, and finalizing case documents are not compensable because they are clerical tasks
The court also reduced the award for: hourly rate reduced, hourly rate reduced.
Why it matters
The ruling shows that a fee award can be cut even when the overall request is substantial. Courts will lower hourly rates and reduce or disallow entries that lack detail or describe clerical tasks, so the description of each time entry affects what is compensable.
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
Freeman v. Smith, No. 3:18-cv-00372 (D. Or. Mar. 12, 2024) See hourly rates the D. Oregon approves and attorney fee motions in Oregon 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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