E.D. Louisiana cuts civil rights fee award 9.8%, including for block billing

What happened

The fee applicant sought $29,670.30 in attorney fees under 42 U.S.C. § 1988. The court awarded $26,770.30, a reduction of $2,900 or 9.8%. It found block billing and vague entries on some tasks, allowing at most four hours as reasonable for those tasks at reduced levels. It also found excessive hours, allowing two hours for some tasks and four hours for others, and held that 15.62 hours spent on two fee motions and other work was excessive.

What the court said

We are able to discern at most four (4) hours of time as reasonable for the above-noted tasks.

Here, although counsel has block-billed and not adequately documented those tasks, it would appear the entries are, nevertheless, compensable at reduced levels.

The court also reduced the award for: excessive hours, excessive hours, excessive hours.

Why it matters

The ruling shows that courts will reduce fee awards when time entries are block billed or vague, even if the work is compensable, and will also trim hours the court considers excessive. It illustrates that a fee petition's time records are scrutinized task by task, with the court setting its own reasonable hours.

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. Louisiana approves and attorney fee motions in Louisiana 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.