M.D. Georgia cuts consumer protection fee award 71.4%, including for vague entries

What happened

Consumer Dispute Lawyers requested $42,881.20 in fees. The court awarded $12,281.20, a reduction of $30,600.00 or 71.4%. It excluded 2.2 hours billed by administrative assistants for vague entries, struck 12.15 hours for unrelated claims, and found 23.6 hours of email entries too vague to assess. It also set lower reasonable hourly rates based on the attorney's experience and disallowed paralegal rates for clerical tasks.

What the court said

The Court therefore excludes those 2.2 hours from the total hours billed by administrative assistants when calculating the lodestar.

The Court finds that 23.6 hours of the email entries billed by Schwartz are so vaguely described that it is impossible to tell whether they were reasonably expended

Plaintiff is not entitled to fees at the paralegal rate for the hours billed by Consumer Dispute Lawyers' administrative assistants on purely clerical tasks.

The court also reduced the award for: unrelated claims, hourly rate reduced.

Why it matters

The ruling shows that courts will exclude time entries too vague to assess reasonableness and will separate clerical tasks from legal work. It also confirms that hourly rates are set by the forum and experience, not by the rate requested, and that time on unrelated claims is not compensable.

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 M.D. Georgia approves and attorney fee motions in Georgia 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.