D. Oregon cuts fee award 3.1%, including for clerical work

What happened

The fee applicant sought $73,189 in fees and costs in Holt v. Urban League of Portland, Inc. et al. Magistrate Judge Youlee Yim You recommended awarding $70,904, a reduction of $2,285 or 3.1%. The court found that Hillas and Whitney billed at the paralegal rate for tasks such as preparing copies, mailing, calculating billed amounts, and filing documents. It also reduced the hourly rate for the remaining 7.9 hours of paralegal work.

What the court said

A review of the time records shows both Hillas and Whitney billed at the paralegal rate for work such as preparing copies, mailing, calculating total billed amounts, and filing documents.

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

Why it matters

The ruling shows that courts review time entries for tasks billed at professional rates that are clerical in nature, and that a reduced rate may apply to remaining work. It also shows that a fee award can be trimmed even when the overall reduction is small.

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 D. Oregon approves and attorney fee motions in Oregon 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.