D. Kansas cuts civil rights fee award 18.3%, including for vague entries

What happened

The plaintiff in a civil rights case sought $317,140 in attorney fees under 42 U.S.C. § 1988. The court awarded $259,233, a reduction of $57,907 or 18.3%. It deducted 9.45 hours for vague time entries and 20.95 hours for clerical or administrative tasks billed as legal work. It then applied a 15% reduction to the lodestar for limited success, balancing the significance of the plaintiff's success against the occasionally scattershot way the case was prosecuted.

What the court said

The Court agrees that a 9.45-hour reduction for the vague entries identified in Doc. 190-2 is appropriate.

The Court agrees that the identified entries are for time spent on clerical or administrative tasks and deducts 20.95 hours.

The court also reduced the award for: limited success.

Why it matters

The ruling shows that courts will reduce fee awards for time entries that lack sufficient detail and for clerical tasks billed at legal rates, and will separately adjust the lodestar when the plaintiff's success is limited relative to the scope of the litigation.

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

See hourly rates the D. Kansas approves.

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.