E.D. California cuts immigration fee award over block billing

What happened

The fee applicant sought attorney fees under the Equal Access to Justice Act in an immigration case. The magistrate judge recommended an award, with figures including costs, but reduced the request by 3.5 paralegal hours entered on April 2, 2026. The court found those hours impermissibly block billed, which it said made it impossible to confirm that the time was not duplicative or clerical. No dollar totals were stated.

What the court said

the undersigned finds that the 3.5 hours spent by the paralegal on April 2, 2026 is impermissibly block-billed, which makes it impossible for the undersigned to confirm that the time expended is not duplicative or clerical.

Why it matters

The ruling shows that a single block-billed time entry can cost hours on a fee petition, even in a recommended award. Where a court cannot separate compensable work from duplicative or clerical tasks within an entry, it may decline to award the time at all rather than estimate a reasonable portion.

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 E.D. California approves and attorney fee motions in California 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.