E.D. New York cuts wage and hour fee award 57.7%, including for vague entries

What happened

Troy Law sought $182,831.83 in fees for 688.12 hours in the Wang wage and hour litigation. The court reduced the hourly rates for each timekeeper, with half rates for travel and clerical tasks. It then cut the billed hours by 30% because entries were vague, duplicative, or excessive, staffing overlapped, and clerical work was billed at associate or partner rates. The court awarded $77,317.25 for 412.85 hours, a reduction of $105,514.58.

What the court said

Several of counsel’s billing entries are vague, duplicative, or excessive, warranting a reduction in the number of hours billed.

the billing records here reflect clerical-work entries billing at associate or partner-level rates

The court also reduced the award for: hourly rate reduced, hourly rate reduced, hourly rate reduced, hourly rate reduced, duplicative staffing, excessive hours.

Why it matters

The ruling shows that a fee award can be reduced on two fronts: the rates claimed and the hours recorded. Where entries are vague, duplicative, or excessive, and clerical tasks are billed at professional rates, courts may apply a percentage cut across the hours rather than parse each entry.

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. New York approves and attorney fee motions in New York federal courts.

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