S.D. Florida cuts commercial fee award 24.4%, including for block billing

What happened

The fee applicant sought $640,922.75 under a contract fee clause. The court awarded $484,623.95, a reduction of $156,298.80. It reduced the hourly rates for the two attorneys. It then reduced the claimed hours by 25% for excessive hours, by 25% for block billing throughout the invoices, by 25% for duplicative staffing among attorneys, legal assistants, and paralegals, and by 25% for clerical tasks billed as legal work.

What the court said

there is a plethora of block billing throughout the invoices

counsel and/or their assistants billed for tasks such as filing various documents with the Court. Entries for clerical or administrative tasks should be excluded.

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

Why it matters

The ruling shows that a fee applicant's time records can draw separate percentage cuts for distinct problems, and that block billing and clerical entries are treated as recordkeeping defects that reduce the compensable hours even when other grounds for reduction also apply.

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 S.D. Florida approves and attorney fee motions in Florida 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.