Sixth Circuit cuts civil rights fee award 62.3%, including for vague entries

What happened

HRT Enterprises, represented by Mark Granzotto, P.C., sought $1,796,626.87 in fees under 42 U.S.C. § 1988 for 3,169 hours. The court awarded $677,880, a reduction of $1,118,746.87 or 62.3%, covering 2,259.6 hours. It applied a 33% discount against total hours for unrelated claims and a 33% discount for vague entries and hours commingled across separate matters. It also reduced the hourly rate, setting it at the overall market average based on a state bar report of median rates.

What the court said

HRT had provided "poor descriptions" for several entries and commingled numerous hours "expended in several entirely separate matters, for which they have no legal grounds for seeking an award of fees."

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

Why it matters

The ruling shows that appellate courts will uphold substantial cuts where billing records mix unrelated matters and give poor descriptions, and that a market average rate from a bar report can replace requested rates.

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

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.