D. Idaho cuts commercial fee award 3.3% over missing contemporaneous records

What happened

The plaintiffs sought $91,315.50 in attorney fees under a contract fee clause. The court awarded $88,300.50, a reduction of $3,015.00, or 3.3%. The court denied the portion of the request covering time after August 13, 2024 because plaintiffs' counsel submitted no billing records to substantiate that amount. The figures do not include costs.

What the court said

Plaintiff's counsel did not submit any billing records to substantiate the additional $3,015.00 requested for the time period following August 13, 2024. Accordingly, the request for these fees will be denied

Why it matters

The ruling shows that a fee request unsupported by contemporaneous billing records can be denied in full for the uncovered period, even where the rest of the request is granted. Courts treat time records as the evidentiary basis for any award, and a gap in the records leaves the court with nothing to review.

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 D. Idaho approves and attorney fee motions in Idaho 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.