D. Puerto Rico cuts employment fee award 21.8%, including for block billing

What happened

González Muñoz Law Offices, PSC, sought $380,100 in fees under 42 U.S.C. § 1988. The court awarded $297,328.16, a reduction of $82,771.84 or 21.8%. It cut each block-billed entry by 20%, removing 13.84 hours, and reduced eight single-task entries by 30% (0.60 hours) and certain entries by 30% (0.15 hours) for lack of detail. It then reduced the lodestar by 20% for limited success, or $74,332.04.

What the court said

the Court will simply reduce each block-billed entry by twenty percent overall, for a reduction of 13.84 hours from Mr. González's time

Eight of Mr. González's problematic time entries consisted of a single task description and will be reduced by thirty percent, for a reduction of 0.60 hours

to adjust for the lack of detail in the above entries provided by Mr. Rivero, the Court will reduce them by thirty percent, for a reduction of 0.15 hours

The court also reduced the award for: limited success.

Why it matters

The ruling shows that courts will trim fee awards when time entries are block-billed or too vague to assess, applying percentage cuts to affected entries rather than parsing each one. It also shows that recordkeeping problems can compound with a separate limited-success reduction applied to the whole lodestar.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the D. Puerto Rico approves.

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