E.D. California cuts consumer protection fee award 80.5%, including for vague entries

What happened

Plaintiffs in Gaines et al v. FCA US, LLC sought $37,365.68 in fees. The court awarded $7,300, a reduction of $30,065.68 or 80.5%. It found the requested fees duplicative, vague, cumulative, and inclusive of work that should not reasonably be done post-settlement, as well as block billing and administrative tasks. The court also denied $3,500 in fees on fees because the fee statute authorizes only actual time expended.

What the court said

a number of Plaintiffs' counsel's requested fees are duplicative, vague, cumulative, and include work that should not reasonably be done post-settlement, as well as block billing and administrative tasks

a number of Plaintiffs' counsel's requested fees are duplicative, vague, cumulative, and include work that should not reasonably be done post-settlement, as well as block billing and administrative tasks

a number of Plaintiffs' counsel's requested fees are duplicative, vague, cumulative, and include work that should not reasonably be done post-settlement, as well as block billing and administrative tasks

The court also reduced the award for: duplicative staffing, other, fees on fees.

Why it matters

The ruling shows that a fee award can be cut sharply when time records are vague, block billed, or mix clerical tasks with legal work, and that courts may refuse fees on fees when the statute limits recovery to actual time expended.

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

See hourly rates the E.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.