N.D. California cuts commercial fee award 7.8%, including for clerical work

What happened

The fee applicant sought $93,226 in attorneys' fees under a contract fee clause. Judge Beth Labson Freeman deducted $2,720 for eight hours of secretarial work billed as legal work, then applied a 5% reduction, or $4,525.30, to account for time spent on a rescission claim. The court awarded $85,980.70, a total reduction of $7,245.30, or 7.8% of the amount requested.

What the court said

Deducting the fees for eight hours of secretarial work ($2,720) from the total fees requested ($93,226)

The court also reduced the award for: unrelated claims.

Why it matters

The ruling shows courts will separate clerical tasks from legal work when reviewing time records, deducting those hours before applying any percentage cut for unrelated claims. It also shows a percentage reduction can be layered on top of line-item deductions, so the final award reflects both the specific entries struck and a broader discount.

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

See hourly rates the N.D. California approves and attorney fee motions in California 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.