S.D. Florida cuts wage and hour fee award 31.3%, including for clerical work

What happened

The plaintiff in an FLSA wage and hour case requested $14,025 in attorney fees. The court awarded $9,630, a reduction of $4,395 or 31.3%. It excluded $4,320 in post-March 21 fees listed in the fee ledger, $1,620 for 3.6 hours sought in the reply brief for fee review and drafting, and entries the court found to be unrecoverable clerical work billed as legal work.

What the court said

The above entries represent unrecoverable clerical work.

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

Why it matters

The ruling shows courts will separate clerical tasks from legal work and decline fees for time spent litigating the fee request itself. It also shows that entries outside the compensable period and reply-brief requests can be cut even when the overall request is modest.

How to keep this out of your fee petition

• Leave purely clerical work off the fee petition.
• Describe paralegal tasks so the substantive work is clear.
• Split mixed entries into their substantive and clerical parts.

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.