D. Hawaii cuts ERISA benefits fee award 21.8% over vague entries

What happened

The fee applicant sought $19,019.65 in fees and costs, covering 60 hours, in an ERISA benefits case. The court awarded $14,868, including costs, a reduction of $4,151.65 or 21.8%. The court deducted 9.6 hours from the time billed because the entries were vague, leaving 50.4 hours awarded. The court applied no other reductions.

What the court said

Accordingly, the Court deducts 9.6 hours from the time billed.

Why it matters

The ruling shows that a fee petition can lose hours even when the only problem is how time was described. Courts will deduct time whose entries do not show what work was done, so the description in the time record itself affects the amount awarded.

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. Hawaii approves and attorney fee motions in Hawaii federal courts.

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