First Circuit cuts employment fee award over vague entries

What happened

Gonzalez Muñoz Law Offices, P.S.C., counsel for the fee applicant in a Title VII employment case, sought fees, and the district court awarded them with reductions. The district court discounted 14.59 hours because of vague entries and applied a twenty percent downward adjustment to the total fee for block billing. The figures include costs. On appeal, the First Circuit, with Judge Hamilton, reviewed and upheld the reductions.

What the court said

the district court discounted 14.59 hours.

the district court applied a twenty percent downward adjustment

Why it matters

The ruling shows that appellate courts will defer to district courts that trim fee awards when time records are vague or block billed, even without stating dollar totals. Lawyers submitting fee petitions should expect scrutiny of entry specificity and task separation.

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.