E.D. California cuts civil rights fee award, including for block billing

What happened

The plaintiffs sought attorney fees under 42 U.S.C. § 1988. The court reduced the lodestar for several reasons: it cut attorney Holm's hours to 471.5, applied 10% reductions to block-billed and vague entries for several attorneys, imposed a 30% cut on 15-hour trial day entries and other deductions for duplicative staffing, disallowed excessive hours, eliminated clerical hours, deducted 15 hours of travel time, and applied a 7.5% reduction for limited success.

What the court said

the court will reduce the number of hours spent by attorney Henderson and attorney Galipo by ten percent, or 1.4 hours and 1.9 hours respectively.

the court will reduce the number of hours spent by attorney Henderson and attorney Galipo by ten percent, or 1.4 hours and 1.9 hours respectively.

the court determines that a ten percent reduction is warranted regarding 121.1 hours billed by attorney Holm

67.5 hours billed by attorney Carrazco

111.1 hours billed by attorney Galipo

177.4 hours billed by attorney Kent Henderson

Mr. Gallegos' time will be reduced by 0.5 hours

Ms. Gomez's hours will be reduced by 69.5 hours and therefore eliminated

Ms. Arraiga's hours will be reduced by 59.2 hours

Ms. Laurel's hours will be reduced by 7.75 hours

the court will deduct them from the billed hours on that ground.

The court also reduced the award for: excessive hours, duplicative staffing, duplicative staffing, duplicative staffing, duplicative staffing, excessive hours, excessive hours, excessive hours, excessive hours, excessive hours, travel time, limited success.

Why it matters

The ruling shows courts will reduce fee awards when time records are block-billed, vague, or include clerical tasks, and when staffing is duplicative. It also confirms that even a largely successful plaintiff may face a modest reduction for limited success.

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. California approves and attorney fee motions in California 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.