D. Puerto Rico cuts employment fee award 14.6%, including for vague entries

What happened

The fee applicant in this Title VII employment case asked the District Court for $185,689.5 in attorney fees. Judge Besosa awarded $158,522.5, a reduction of $27,167. The court cut by 50 percent the hours claimed on January 16 and 17, 2024 by Mendoza-Mendez and Mendoza-Sanchez for Rule 30(b)(6) deposition preparation, citing vague entries. It also cut by 50 percent a 6.5-hour entry that billed several distinct tasks together, because the tasks could not be separated for review. The court also lowered hourly rates to the district's prevailing rates and applied a lower rate to fee petition work.

What the court said

The Court adjusts downward by 50 percent the hours claimed on January 16 and 17, 2024 by Mendoza-Méndez and Mendoza-Sánchez for Rule 30(b)(6) deposition preparation.

This entry bills a collective 6.5 hours for several distinct tasks. Because the Court cannot separate these tasks and assess whether the time spent on each was reasonable, this entry will also be discounted by 50 percent.

The court also reduced the award for: hourly rate reduced, fees on fees.

Why it matters

The ruling shows that a fee applicant's time records are the basis for the award. Entries that do not identify the work performed, and entries that combine several tasks into one block of hours, can each draw a percentage cut, even where the overall request is otherwise granted in part.

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. Puerto Rico approves.

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