Bankr. D. Montana cuts bankruptcy fee award 72.5%, including for block billing

What happened

The applicant sought $45,510.20 in fees for 152.3 hours. The court awarded $12,500, a reduction of $33,010.20 or 72.5%. It found the hours excessive and concluded that a reasonable award fell within a range it identified. It also found duplication after scrutinizing the time records, noted lumped entries in the block billing, though not a persistent problem, and disallowed a charge for reviewing and discussing the confirmation order because the fee provision applies only post-petition and pre-confirmation.

What the court said

Although not a persistent problem, Applicant’s time records included lumped entries.

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

Why it matters

The ruling shows that a fee award can be cut sharply when time records show excessive hours and duplication, and that even occasional lumped entries draw scrutiny. It also shows courts will separate charges tied to work outside the period covered by the fee provision.

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

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.