W.D. Tennessee cuts commercial fee award 12.4%, including for block billing

What happened

HYC Logistics sought $513,846.50 in attorney fees under a contract fee clause, with Glankler Brown, PLLC as counsel. The court awarded $450,000, a reduction of $63,846.50 or 12.4%. It excluded $84,819.50 for claims against Weiss as unrelated to the collection costs. It lowered associate and paralegal hourly rates and declined an hourly rate increase. It also reduced fees for block billing, such as 4.10 hours for trial prep without detail, and vague entries.

What the court said

Kahane billed 4.10 hours for "Trial Prep." But Kahane never described what exactly that preparation entailed. And there are many similar entries.

But Kahane never described what exactly that preparation entailed. And there are many similar entries. This type of billing may work for some clients. But in this context, it hinders the Court's ability to decide whether such entries are reasonable.

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

Why it matters

The ruling shows courts will reduce fees when time entries do not explain the work performed, even alongside rate and scope adjustments. Block billing and vague descriptions can hinder review of reasonableness, and the court applied several reductions rather than crediting any single recordkeeping problem with the whole cut.

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 W.D. Tennessee approves and attorney fee motions in Tennessee 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.