E.D. Michigan cuts civil rights fee award 21.2%, including for vague entries

What happened

The plaintiff in a civil rights case sought $8,085.20 in attorney fees. Judge Judith E. Levy awarded $6,370.32, a reduction of $1,714.88 or 21.2%. The court reduced the hourly rate, excluded 2.0 hours because it would not serve the interests of justice for the defendant to pay for that filing, and declined to award 1.0 hour for a September 6, 2024 entry described as file entry of default, which the court found vague. The awarded hours totaled 16.72.

What the court said

As such, the September 6, 2024 entry for “file entry of default” is vague and will not be awarded.

The court also reduced the award for: hourly rate reduced, other.

Why it matters

The ruling shows that a fee petition can lose time for entries too general to show what work was done, even when the overall request is modest. It also shows courts will adjust the hourly rate and exclude time for reasons unrelated to recordkeeping, so the final award reflects several separate reductions.

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