First Circuit cuts employment fee award, including for vague entries

What happened

Gonzalez Muñoz Law Offices, P.S.C., counsel for García, sought fees under Title VII. The district court discounted eight entries by 30 percent, removing 0.60 hours, and another entry by 30 percent, removing 0.15 hours, because the entries were vague. It then applied a 20 percent downward adjustment for limited success, citing an unsuccessful sexual harassment claim and denial of permanent injunctive relief. The First Circuit, in an opinion by Judge Hamilton, reviewed and upheld the reductions. The figures include costs.

What the court said

The district court discounted each of the eight other entries by thirty percent, effectively removing 0.60 hours from the fee-award calculus.

the district court discounted each entry by thirty percent, resulting in a reduction of 0.15 hours from his time.

The court also reduced the award for: limited success.

Why it matters

The ruling shows that appellate courts will defer to district courts that trim time for entries lacking detail, even when the hours removed are small, and that vague descriptions can draw percentage discounts rather than outright exclusion. It also confirms that limited success can support a separate across-the-board cut after the lodestar is calculated.

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

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.