D. Montana cuts sanctions fee award 50.2%, including for block billing

What happened

Giacometto Ranch Inc. and others sought $20,095.93 in sanctions fees, an amount that includes costs. The District Court awarded $10,000, a reduction of $10,095.93 or 50.2%. The court found that both firms block-billed to some extent, which left it unclear whether the full amount was attributable to the motions or to other tasks lumped together. The court also found it unreasonable to seek fees for attending a mediation and reviewing unrelated documents, and the block-billed entries prevented it from separating those fees.

What the court said

Both firms block-bill to some extent, further calling into question whether the entire $100,479.66 is truly attributable to the motions filed by Giacomettos or a mixed bag of other tasks lumped together.

The court also reduced the award for: unrelated claims.

Why it matters

The ruling shows that block billing can limit a fee award even when the total is modest, because it leaves the court unable to separate compensable work from unrelated tasks. Where entries combine mediation, document review, and motion work, the court may reduce the award rather than attempt to reconstruct the time.

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. Montana approves.

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