S.D. Florida cuts commercial fee award 17.3%, including for block billing

What happened

Smith, Currie & Hancock, LLP sought $484,298.50 in fees under a contract fee clause. The court awarded $400,502.50, a reduction of $83,796.00 or 17.3%. It lowered several hourly rates for attorneys and paralegals. It applied 10% and 25% across-the-board cuts for block billing, clerical work billed as legal work, travel time, and unrelated claims, and excluded 9.7 hours of duplicative and vague entries and 2.0 hours of clerical paralegal time.

What the court said

there are some unreasonable hours billed which necessitate a 10% across-the-board reduction.

there are several occasions where Smith Currie billed hours for ministerial clerical tasks that litigation support specialist Alvarez performed.

there were several instances where attorney Scherer engaged in impermissible block-billing.

paralegal Maya billed an hour for purely ministerial clerical tasks

None of these entries explain which issues or documents he is analyzing or reviewing.

the two hours paralegal Aldama billed were entirely clerical

The court also reduced the award for: hourly rate reduced, hourly rate reduced, hourly rate reduced, hourly rate reduced, hourly rate reduced, travel time, unrelated claims, duplicative staffing.

Why it matters

The ruling shows courts will reduce rates and apply percentage cuts when time entries combine tasks, bill clerical work as legal work, or lack detail. It also shows that entries for travel and unrelated claims can draw reductions, and that vague or duplicative entries may be excluded hour by hour.

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 S.D. Florida approves and attorney fee motions in Florida 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.