E.D. California cuts fee award 56.8%, including for missing contemporaneous records

What happened

The fee applicant requested $19,107.50 in fees. The court awarded $8,250, a reduction of $10,857.50. It reduced the hourly rates for Mr. Riley and the research attorney. It applied an overall 30% reduction to Mr. Riley's billed hours to account for the lack of contemporaneous billing, block billing that included clerical tasks, and unreasonable billing amounts for minor tasks. It also reduced a 2-hour entry and cut another entry from 1.0 to 0.5 hours.

What the court said

The Court finds that an overall 30% reduction in the hours billed by Mr. Riley is appropriate to account for the lack of contemporaneous billing

the block-billing entries including clerical tasks

the block-billing entries including clerical tasks

This entry combines billable and clerical tasks. This was also a routine motion, barely more than a page in length. The Court reduces this entry from 1.0 to 0.5.

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

Why it matters

The ruling shows that a lack of contemporaneous time records can support a percentage reduction across all billed hours, and that block-billed entries mixing clerical tasks with legal work draw scrutiny even when the court also adjusts rates and specific entries.

How to keep this out of your fee petition

• Record time the same day the work happens.
• Keep the original records, not only a cleaned-up summary.
• Be able to show when each entry was created.

Cite this ruling

See hourly rates the E.D. California approves and attorney fee motions in California federal courts.

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